The country of origin of a torque wrench

N355707 November 25, 2025 OT:RR:NC:N1:164 CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn, LLP 303 E. Wacker Drive, Ste. 305 Chicago, IL 60601 RE: The country of origin of a torque wrench Dear Mr. Friedman: In your letter dated November 4, 2025, you requested a country of origin ruling on a torque wrench on behalf of your client, Apex Tool Group. Product and manufacturing information was submitted with your request. The torque wrench under consideration is described as a specialized form of socket wrench used in applications where it is critical to apply the proper amount of force to a bolt head, nut, or other fastener. You specify that the torque wrench at issue features a 1/2-inch drive and is capable of delivering 50-250 foot-pounds of torque. Manufacturing commences in Vietnam where the entire ratchet handle body is forged from steel bar from China. The forging in Vietnam produces a ratchet handle blank that closely approximates the final shape of the finished torque wrench. After forging, the blanks are sent to China where they are machined, heat-treated, plated, assembled with Chinese components, calibrated, and packaged for export. During assembly, a tube and spring of Chinese origin are set into the adjustable handle to set the desired torque. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In this scenario, the forged ratchet handle blanks from Vietnam are exported to China with a pre-determined identity as torque wrenches. It is clear from your description that the ratchet handle is the primary structure upon which a user manually applies desired torque to a fastener. As described, the operations in China amount to finishing processes and simple assembly. Consequently, the forged ratchet handles from Vietnam do not undergo a substantial transformation in China. No article emerges from the operations in China with a new name, character, or use. This determination is similar to that of New York ruling N347937, dated May 6, 2025. Accordingly, the country of origin of the torque wrench will be Vietnam. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (C.F.R.), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 C.F.R. 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division