The country of origin of long nose locking pliers

N358676 March 6, 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 long nose locking pliers Dear Ms. Jin: In your letter dated February 10, 2026, you requested a country of origin determination for the purposes of Section 301 and additional 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 under consideration is identified as a pair of long nose locking pliers. This hand operated tool incorporates adjustable jaws that lock into a fixed position, allowing them to firmly grip and hold objects without the need for continuous hand pressure. The jaws can be tightened by a screw or knob and released by a lever, making them versatile for a wide range of tasks, from gripping and turning nuts to holding parts in place while welding. You have stated that the jaws are made of chrome vanadium steel and the handles are made of alloy steel. The manufacturing process begins in Vietnam, where steel rods are cut and drop-forged to produce the jaws of the pliers in their final dimensions and general shape. These forged jaws are then exported to China where they undergo precision drilling to create the required assembly and functional holes, followed by the machining of both fine and coarse serrations on the gripping surfaces. The jaws are subsequently heat-treated and polished. After these processing steps, the jaws are assembled in China with other components of Chinese origin, including handles, lever, rivets, springs, adjusting screw, and release trigger. The assembled pliers are finally electroplated, resulting in the finished product. 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). In considering your manufacturing scenario, there is no dispute that the two jaws, which are manufactured in Vietnam, are dedicated for use in the finished locking pliers. However, while this is a consideration, it does not assure a finding of substantial transformation. As the court stated in National Hand Tool, we must look at the totality of the evidence. We also must consider the product at issue, how it functions, and the purpose of the components within it carrying out its function. Locking pliers use an adjustable toggle mechanism to clamp onto objects with high pressure without requiring continuous handle squeezing. An adjustment screw sets the jaw distance, while a lever releases the locked grip. These significant Chinese-origin components are essential to the tool’s functionality. Furthermore, the assembly of these components, along with the jaws occurs in China. Therefore, the totality of the evidence leads our office to conclude that the country of origin of the finished long nose locking pliers is China. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division