The country of origin of a 10" Indexing Pry Bar

N357862 January 26, 2026 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 10" Indexing Pry Bar Dear Ms. Jin: In your letter dated January 16, 2026, you requested a country of origin determination for the purposes of Section 301 and IEEPA duties. Pictures of the item in different stages of manufacture were included with your submission, along with a narrative of the manufacturing processes. The merchandise is identified as a 10" Indexing Pry Bar. It is a hand tool constructed from carbon steel that is used for prying, lifting and separating materials. It incorporates a fixed claw head on one end of its body and an adjustable claw head on the other end. The adjustable claw pivots and locks into five different positions by pressing a release button located on the side of the claw. The tool has a length of 10 inches and weighs 0.895 pounds. The manufacturing process for the 10" Indexing Pry Bar begins in Vietnam, where carbon steel is forged into two articles: the adjustable claw head and the body of the tool that includes the fixed claw head. These articles are then sent to China where they undergo machining, polishing, heat treatment and surface treatment. Finally, the two articles are assembled into the finished tool with an end cap, transfer gear and screw sourced from China. 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 10" Indexing Pry Bar, it is our view that carbon steel is substantially transformed in Vietnam, where it is forged into the two fundamental articles of the finished tool. These articles provide the principal characteristics and main functionality of the finished tool, 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" Indexing Pry Bar 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division