The country of origin of a caulking gun

N359646 March 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 caulking gun Dear Ms. Jin: In your letter dated March 11, 2026, you requested a country of origin determination for the purposes of Section 301 and other 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 a manually operated caulking gun that is designed for dispensing caulk, construction adhesive, and sealant materials from standard 10 oz. cartridges. The tool operates through a hand-actuated trigger mechanism that advances a push rod, which applies controlled pressure to the cartridge contents. The caulking gun is equipped with a rotatable barrel to facilitate application in corners and confined areas and includes a cushion-grip trigger for user comfort. The product is constructed primarily of metal components, including the main frame, handle, barrel, push rod and push plate, with plastic and rubber components used for the grip and auxiliary parts. You propose three manufacturing scenarios. The first scenario begins in Vietnam, where aluminum alloy is die-cast to form the main frame and handle of the caulking gun. These cast components subsequently undergo threading and powder coating. Additionally in Vietnam, aluminum alloy is die cast to produce the large nut, which functions as the locking component for the push rod. This large nut then undergoes threading operations to become a finished component. The completed handle, main frame and large nut are subsequently assembled in Vietnam together with other components sourced from China, including the push rod and rotating barrel, to produce the finished caulking gun. Scenario two is similar to scenario one, with the addition of the production of the main body of the rotating barrel in Vietnam. Carbon steel is cut to the specified dimensions and shape for the rotating barrel’s main body, which is then welded to the two side components sourced from China to form a complete rotating barrel. The assembled rotating barrel is subsequently powder coated to produce a finished component. The completed handle, main frame, large nut and rotating barrel are subsequently assembled in Vietnam with other components sourced from China, including the push rod and push plate, to produce the finished caulking gun. Scenario three is similar to scenario two, with the addition of the production of the push rod and concave push plate in Vietnam. Carbon steel is cut to the specified dimensions and shape for the push rod, which is then machined (including face turning and threading) and bent to form the final push rod. The rod is subsequently electroplated to produce a finished push rod component. Additionally, carbon steel is cut to the specified dimensions and shape for the concave push plate, which is then heat-treated and electroplated to form a finished concave push plate component. The completed handle, main frame, large nut, rotating barrel, push rod and push plate are subsequently assembled in Vietnam with other components sourced from China to produce the finished caulking gun. 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). Based on the manufacturing processes described in your three manufacturing scenarios, it is our view that a substantial transformation occurs in Vietnam. In each scenario, significant manufacturing operations are performed in Vietnam, including die-casting aluminum alloy into the main frame and handle, followed by threading and surface finishing to produce completed functional components, as well as the die casting and machining of the large nut that serves as the locking component for the pushing rod. These operations transform raw materials into dedicated components with their final shape, mechanical properties, and specific functions essential to the operation of the caulking gun. Final assembly of the finished caulking gun is also performed in Vietnam, where the Vietnamese manufactured components are combined with other parts sourced from China to produce a completed article of commerce with a name, character, and use distinct from those of the individual components. Therefore, the totality of evidence leads our office to conclude that the country of origin of the finished caulking gun in your three manufacturing scenarios 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division