The country of origin of a universal impact tool

N355862 November 14, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn LLP 303 East Wacker Drive, Suite 305 Chicago, IL 60601 RE: The country of origin of a universal impact tool Dear Mr. Friedman: In your letter dated November 7, 2025, on behalf of your client, Apex Tool Group, 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 narratives of the manufacturing process. The item under consideration is identified as a ½" DR Universal Joint Impact Tool. It consists of a steel impact socket that is attached to a flexible universal joint, which allows it to pivot for reaching fasteners in tight spaces. The universal joint incorporates a ½" drive that connects to an impact socket wrench when in use. The manufacturing process for ½" DR Universal Joint Impact Tool begins in Vietnam, where Chinese-origin steel coils are cold forged into the approximate circumference, length and shape of both the finished impact socket and the universal joint. You have stated that this process is done using a dedicated cold forging machine and a specialized die. After forging, the impact socket and universal joint are shipped to China for finish machining on a lathe, knurling, heat treatment, oxidative blackening as a rust inhibitor, and laser marking. Additional operations include drilling a hole for a retainer ball, heat treatment, anti-rust oxidative coating, and pressing in the retainer ball. Finally, the impact socket and universal joint are permanently affixed. 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 ½" DR Universal Joint Impact Tool, our office notes that the tool is comprised of two main components, i.e., an impact socket and a universal joint. Both components are cold forged from steel coils in Vietnam into recognizable blanks that make up the finished tool. Although not ready for direct use, the tool blanks that arrive in China have a pre-determined use and are in a dedicated physical form of the finished tool. Based on the submitted information and pictures of the finished ½" DR Universal Joint Impact Tool, it is our opinion that no article emerges from the finishing and assembly operations in China with a new name, character, or use different from that prior to processing. Therefore, it is our determination that the country of origin of the ½" DR Universal Joint Impact Tool 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division