The country of origin of scissors from Vietnam.

N355860 December 3, 2025 OT:RR:NC:N4:415 CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn, LLP 303 East Wacker Drive, Suite 305 Chicago, IL 60601 RE: The country of origin of scissors from Vietnam. Dear Mr. Friedman: In your letter dated November 7, 2025, you requested a country of origin ruling on behalf of your client, Apex Tool Group. Images were provided in lieu of a sample. The product under consideration is described as 10-inch all-purpose scissors. Your submission indicates that the production process begins with steel sheets from China that are shipped to Vietnam. In Vietnam, the blanks are formed using a laser cutting machine that cuts the precise shape of each scissor blade blank from the metal sheets. The cut blanks feature the pivot holes where the two blades are connected. At this stage, the blanks already exhibit their final shape, size, and form. The blanks are then sent to China for machine finishing. In China, the blades undergo heat treatment, grinding, coating, honing, and the injection molded handles are attached to complete the finished scissors. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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 order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. This office reviewed the submitted production process for these scissors, and we agree it is like what is described in New York rulings N352762, dated September 12, 2025, and N347613, dated May 6, 2025. Similarly, these blade blanks hold the essential identity of the finished scissors and the further processing in China would not substantially transform them. As such, the country of origin for these 10-inch all-purpose scissors 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 (“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 CBP Regulations (19 CFR 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, contact National Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division