The country of origin of pliers

N356964 December 31, 2025 OT:RR:NC::N1:118 CATEGORY: Origin Yunfang Gao Meridian International Co., Ltd. 1886 Laiyin Road, Songjiang Shanghai 201615 China RE: The country of origin of pliers Dear Ms. Gao: In your letter dated December 12, 2025, you requested a country of origin ruling. Pictures of the items in different stages of manufacture were included with your submission, along with a narrative of the manufacturing process. The items under consideration are five types of pliers, identified as 10" groove joint pliers, 6" diagonal cutting pliers, 8" needle nose pliers, two pairs of 16" long reach pliers, and a four-piece set of tongue and groove joint pliers. You have stated that the manufacturing process for the pliers is identical. The manufacturing process begins in Vietnam, where circular carbon steel is cut to length and then forged into the shape and form of the two halves of the pliers (i.e., the pieces incorporating the handles and jaws). These articles are sent to China where the center pivot hole is drilled into each, followed by additional shaping and assembly. The piers are subsequently heat treated, polished, laser-engraved, and injection molded grips are applied to the handles. Finally, the finished pliers are packaged for shipment to the United States. 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 the country of origin of the five types of pliers, it is our view that raw steel is substantially transformed in Vietnam, where it is cut and forged into the shape and form of the two halves of the pliers (i.e., the pieces incorporating the handles and jaws). These articles provide the principal characteristics and main functionality of the finished tools, are dedicated for use as such, and cannot be used for any other purpose. The character of these articles remains unchanged after the manufacturing processes and assembly operations that occur in China. Therefore, it is the opinion of our office that the country of origin of the 10" groove joint pliers, 6" diagonal pliers, 8" needle nose pliers, two pairs of 16" long reach pliers, and a four-piece set of tongue and groove joint pliers 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division