The country of origin of a 12" Pry Bar

N357864 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 12" 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 12" Pry Bar. It is a hand tool constructed from carbon steel that is used for prying, lifting, pulling nails and separating materials. It incorporates a slightly curved flat claw head on one end of its body and split claw head on the other end, which is bent at a 90-degree angle. You propose two manufacturing scenarios. The first scenario begins in Vietnam, where carbon steel is forged into the overall flat shape and size of the finished tool. This blank is then sent to China, where each claw head is bent to its final angle. Finally, it undergoes heat treatment and surface treatment. The second scenario is similar to the first, except each claw head is bent to its final angle in Vietnam before being sent to China for heat treatment and surface treatment. 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 12" Pry Bar, it is our view that in both your 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 12" 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