The country of origin of a 3-in-1 Camping Tool Combo

N355989 November 24, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a 3-in-1 Camping Tool Combo Dear Ms. Jin: In your letter dated November 13, 2025, you requested a country of origin determination for the purposes of Section 301 and IEEPA duties. Samples of the finished item and a semi-finished article were included with your submission, along with a narrative of the manufacturing processes. The samples will be retained by our office. The item under consideration is identified and marketed as a 3-in-1 Camping Tool Combo. This multipurpose hand tool combines a hatchet for chopping, a handsaw for cutting, and a small mallet that can be used for striking tent pegs into the ground. It consists of a stainless steel hatchet head with a 3.5-inch blade and a small mallet head incorporated on to the back side of the head. The 10-inch carbon steel saw blade is stored in the plastic hatchet handle of the tool when not in use. The back side of the plastic hatchet handle completely covers the small mallet head and serves as its striking surface. A plastic sheath covers the hatchet head when not in use and functions as a handle for the saw blade. To use the saw blade, the user attaches it with a screw and clips between the bottom of the plastic sheath and bottom of the hatchet handle. The hatchet handle also incorporates a tensioning mechanism for the saw blade. The manufacturing process for the 3-in-1 Camping Tool Combo begins in Vietnam, where stainless steel is stamped into the size and shape of the hatchet head. The head is then sent to China for further machining, heat treatment, black oxide finishing, laser engraving, and sharpening. The 10-inch carbon steel saw blade, nylon and fiberglass hatchet handle, plastic sheath and all other components used in assembly are of Chinese origin. These components are assembled with the hatchet head in China to form the finished tool. In its retail packaging, the 3-in-1 Camping Tool Combo resembles both a hatchet and a bow saw. 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). Regarding the finished 3-in-1 Camping Tool Combo, we note that the tool is marketed and sold as a multifunctional versatile tool. The hatchet blade and saw blade are of equal prominence and importance to its overall function. When the Chinese-origin saw blade is in use, the hatchet head’s plastic sheath is used as a handle, and the tool takes on the appearance of a bow saw. Furthermore, the hatchet handle acts as storage for the saw blade when not in use. These Chinese components, along with other Chinese components used for assembly, are of critical importance to the overall functionality of the tool. Considering the totality of the circumstances, it is our view that the stainless steel hatchet head undergoes a substantial transformation into a multifunctional tool in China. Accordingly, the country of origin for the 3-in-1 Camping Tool Combo is China. 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