The country of origin of linesman pliers

N357111 January 7, 2026 OT:RR:NC:N1:118 CATEGORY: Origin Vincent Liu Kunjek Industry 929 N Grand Ave. Covina, CA 91724 RE: The country of origin of linesman pliers Dear Mr. Liu: In your letter dated December 17, 2025, you requested a country of origin ruling on linesman pliers. Pictures of the tool in different stages of manufacture were included with your submission, along with a narrative of the manufacturing processes. Linesman pliers are a type of pliers used by linemen, electrical contractors, and other tradesmen primarily for gripping, twisting, bending, and cutting wire, cable, and small metalwork components. They are made of two pieces of steel, with each piece providing half of the handle and half of the working end. They have a beveled cutting edge near the joint of the working end’s jaw and teeth for gripping at the end of the nose. You have stated that the linesman pliers will be imported in different lengths. However, the manufacturing processes will be the same. The manufacturing process for the linesman pliers involves drop-forging raw steel rods in Thailand into the shape and form of the two halves of the pliers (i.e., the pieces incorporating the handles and jaws). They are further trimmed and punched before being sent to China, where they are drilled with holes for assembly and teeth are milled into the jaws. Subsequently, the two halves are assembled by a rivet machine and then heat treated and polished. The handles are coated with either single dip or double dip plastic. Finally, the pliers are laser marked with a logo and packaged for retail sale. 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 linesman pliers, it is our view that raw steel is substantially transformed in Thailand, where it is forged and cut 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 linesman pliers 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