The country of origin of a pry bar

N356772 December 31, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Eric Lee Zhangjiagang Tianhua Hardware Co., Ltd. 26 Xinle Road, Daxin Town, Zhangjiagang City Jiangsu Province Zhangjiagang 215636 China RE: The country of origin of a pry bar Dear Mr. Lee: In your letter dated December 7, 2025, you requested a country of origin ruling. Pictures of the item in different stages of manufacture were included with your submission, along with a narrative of the manufacturing processes. The item under consideration is identified as a pry bar (also referred to as a crowbar or wrecking bar). It is a hand tool used for prying, lifting, or moving heavy objects. The tool consists of a long steel bar with a flattened chisel end and a curved or angled claw end for leverage. The manufacturing process for the pry bar begins in Thailand, where steel coil is straightened and cut into a flat steel bar. The steel bar is then heated and drop-forged into the bar body and functional ends, i.e., the chisel tip and claw, of the finished pry bar. The article is subsequently sent to China for machining, heat treatment, surface finishing, and packaging. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding pry bar, it is our view that steel is substantially transformed in Thailand into a recognizable blank of the finished pry bar. This consists of the final functional shape with the chisel and claw ends. Based on the submitted information and pictures, it is our opinion that no article emerges from the finishing operations in China with a new name, character, or use different from that prior to processing. Although not ready for immediate use, the blank that arrives in China has a pre-determined use and is in a dedicated physical form of a pry bar. It is therefore our opinion that the country of origin of the finished pry bar is Thailand. 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