The country of origin of a handsaw

N355777 November 10, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Anne Brandon Yormick Law LLC 5900 Landerbrook Drive, Suite 205 Cleveland, OH 44124 RE: The country of origin of a handsaw Dear Ms. Brandon: In your letter dated November 5, 2025, on behalf of your client, The Davidson Works Co., Ltd., you requested a country of origin determination for purposes of Section 301 and IEEPA duties. Pictures of the item in different stages of manufacture were included with your submission, along with a narrative of the manufacturing process. The merchandise under consideration is a handsaw, which consists of a steel blade attached to a plastic and rubber handle. You have stated that this particular style of handsaw will be manufactured in a variety of sizes, including 6", 8", 10", 12", 14", 15", and 20". The manufacturing process for the different sizes will be the same. In Vietnam, coiled steel sheets are fed into a laser cutter that cuts the sheets into blanks, which have the overall size and shape of a finished blade. The blanks are fed into a gear grinding machine that grinds teeth into the blank. The semi-finished blades are subsequently surface cleaned, polished, deburred, and heat treated to enhance hardness. Each blade is further processed through a teeth setting machine, which alternately bends the teeth outward to ensure proper cutting performance. The blades are then painted before export to China, where they are fed into a printing machine that prints customer specifications onto each blade. Finally, the blades are assembled with plastic and rubber handles, tooth guard covers are put over the blades for protection, and the finished handsaws are packaged for shipment. When determining the country of origin for purposes of applying current trade remedies under Section 301 and other 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). Regarding the finished handsaw, it is our view that coiled steel sheets are substantially transformed in Vietnam into handsaw blades. This includes creating blanks, grinding teeth into the blanks, and alternately bending the teeth outward to ensure proper cutting performance. It is the handsaw blade that contributes to the main functionality of each finished handsaw. Based upon the provided descriptions and pictures of the finishing operations performed in China, the handsaw blades are not substantially changed so as to transform them into new articles with a different name, character, or use. It is therefore the opinion of our office that the country of the finished handsaw is 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 (CFR), 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 CFR 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 Anthony Grossi at anthony.e.grossi@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division