The country of origin of a 13" Cat’s Paw Pry Bar

N357863 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 13" Cat’s Paw 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 13" Cat’s Paw Pry Bar. It is a hand tool constructed from carbon steel that is used for extracting nails from wood and other materials. It incorporates a sharp-tipped, V-notch nail puller (i.e., the cat’s paw) on one end with a curved, rocker-type notched head on the other end. This enables the tool to pull nails straight out using a rocking motion rather than a twisting pry. You propose three manufacturing scenarios. The first scenario begins in Vietnam, where carbon steel is forged into the rough shape of the body of the pry bar. This includes the cat’s paw end of the tool. This article is then sent to China, where the other end of the bar is bent to its final shape, it is polished, heat treated and surface treated. Finally, it is assembled with a Chinese-origin rocking arm, rivet and washer. The second manufacturing scenario is similar to the first scenario, except the rocking arm is also forged in Vietnam and sent to China along with the body of the pry bar. Once in China, the two articles are bent to their final shape, polished, heat treated and surface treated. Lastly, the body of the pry bar and the rocking arm are assembled with a rivet and washer. The third manufacturing scenario is similar to the second scenario, except the body of the pry bar and the rocking arm are bent to their final shape in Vietnam. The two articles are then sent to China where they are polished, heat treated and surface treated. Finally, the body of the pry bar and the rocking arm are assembled with a rivet and washer. 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 13" Cat’s Paw Pry Bar, it is our view that in your three manufacturing scenarios carbon steel is substantially transformed in Vietnam, where it is forged into a recognizable blank of the finished tool. 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. It is therefore our opinion that the country of origin of the finished 13" Cat’s Paw 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