The country of origin of 12-in-1 Ratcheting Stubby Screwdriver

N359908 April 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 12-in-1 Ratcheting Stubby Screwdriver Dear Ms. Jin: In your letter dated March 19, 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 identified as a 12-in-1 Ratcheting Stubby Screwdriver. It is a hand-operated tool used for driving and removing screws in confined spaces. The tool consists of a steel shaft with a ratcheting function, six double-end chrome plated bits, and a plastic handle. You propose two manufacturing scenarios. The first scenario begins in Vietnam, where raw steel coil is cut to specified lengths to create six bit blanks, each end of which is subsequently machined to form distinct driver tip configurations (e.g., Phillips, slotted, or Torx). Separately, the shaft is also produced in Vietnam from raw steel coil. The coil is cut to length, cold-forged to the final diameter, and cold-forged to incorporate a hexagonal internal bore. Further machining operations include forming the ratchet teeth, finishing the shaft tail and processing the shaft head. The shaft and bits are then exported to China, where they are subjected to heat treatment and electroplating, followed by final assembly with China-sourced components, including a lock ring, ratchet base, socket cap and plastic handle. The second manufacturing scenario is similar to the first, except the shaft is further machined in China rather than Vietnam. This includes forming the ratchet teeth, finishing the shaft tail and processing the shaft head. 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 two manufacturing scenarios, it is our view that a substantial transformation occurs in Vietnam. In both scenarios, raw steel coil is cut and cold-forged into the defined shape of the six double end bits and the steel shaft. These components 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 12-in-1 Ratcheting Stubby Screwdriver 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 P. Forkan Director National Commodity Specialist Division