The country of origin of a tool set and a socket extension bar

N356018 December 4, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn, LLP 303 E. Wacker Drive, Ste. 305 Chicago, IL 60601 RE: The country of origin of a tool set and a socket extension bar Dear Mr. Friedman: In your letter dated November 13, 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 items in different stages of manufacture were included with your submission, along with narratives of the manufacturing processes. The first item under consideration is identified as a 45PC 1/4" DR 6PT Mechanics Tool Set, which includes one ratchet handle, two extension bars and thirty-seven various sizes of sockets. You have stated that the set also includes five Chinese-origin bit sockets. The second item is identified as a 1/2" Drive Extension 10". You have stated that the manufacturing process for the 1/2" Drive Extension 10" is identical to that of the extension bars included in the 45PC 1/4" DR 6PT Mechanics Tool Set. Apart from the five Chinese-origin bit sockets, the manufacturing process for each of the steel tools begins in Vietnam. Chinese-origin steel is cold forged and pressed into blanks of the ratchet handle, extension bars and sockets. The pictures you submitted indicate that these blanks are in the approximate size and shape of the finished tools. The blanks are then sent to China for further finishing operations. The ratchet handle blank undergoes grinding, CNC lathe machining (turning, milling, making holes, hydraulic pressing, belt sanding) stamping, quenching, vibratory finishing, and electroplating. Components are then assembled and installed into the ratchet handle’s circular head to complete the ratcheting mechanism. The extensions blanks have holes drilled into their heads, are heat treated, plated, and stamped. Steel retention balls are then pressed into the drilled holes. The socket blanks undergo centerless grinding, marking, heat treating, and vibrate-plating. Some socket heads have press-steel ball toppers added and undergo drilling in order to fit the steel balls. Finally, the finished ratchet handle, extension bars and sockets are packaged for retail sale with the Chinese-origin bit sockets to complete the 45PC 1/4" DR Mechanics Tool Set. 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). According to the CBP website under Section 301 Trade Remedies Frequently Asked Questions, “When importing goods put up in sets for retail sale (in accordance with General Rule of Interpretation 3) that contain articles subject to the Section 301 remedy, if the product that imparts the essential character to the set (i.e., the tariff provision under which the entire set is classified) is covered by the Section 301 remedy, then the entire set will be subject to the additional duties. If the tariff provision under which the entire set is classified is not covered by the Section 301 remedies, but the set contains components that are classified in a subheading covered by the 301 list, the 301 duties will not be assessed on the individual components.” In regard to the 45PC 1/4" DR 6PT Mechanics Tool Set, the ratchet handle is the central attachment point and mechanism for the sockets, extensions and socket bits holders. Without the ratchet handle to provide ratcheting and torque transmission, the practical usefulness of the sockets, extensions and socket bits is significantly hampered because the ability to deliver torque to fasteners is substantially harmed. Since the overall functionality of the set is largely dependent on the mechanical capabilities and unique physical features of the ratchet handle, it is the component which gives the tool set its essential character. Regarding the country of origin of the ratchet handle, the forged handle manufactured in Vietnam is exported to China with a pre-determined end use as a type of ratchet handle. Functionally, the forged handle and its circular head enable a user to grip and manually apply the force required to tighten fasteners. In totality, the processing and assembly operations in China do not substantially transform the forging from Vietnam. No article emerges from the operations in China with a new name, character, or use. Accordingly, the country of origin of the ratchet handle will be Vietnam. The ratchet handle of Vietnamese origin imparts the essential character of 45PC 1/4" DR Mechanics Tool Set and thus determines the country of origin of the set. Accordingly, the country of origin of the 45PC 1/4" DR 6PT Mechanics Tool Set is Vietnam. In regard to country of origin of the 1/2" Drive Extension 10", it is our view that raw steel is substantially transformed in Vietnam into a recognizable tool blank. The extension has a pre-determined use and is in a dedicated physical form when it arrives in China. Based on the submitted information and pictures of this item, it is our opinion that it does not emerge from the finishing 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 1/2" Drive Extension 10" 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