The country of origin of three knives.

N362097 June 18, 2026 OT:RR:NC:N4:415 CATEGORY: Origin Matt Nakachi, Esq. Nakachi Eckhardt & Jacobson, PC 50 California Street, Suite 1500 San Francisco, CA 94111 RE: The country of origin of three knives. Dear Mr. Nakachi: In your letter dated June 5, 2026, you requested a country of origin ruling on behalf of your client, GB II, Inc. There are three products under consideration. The first is the Minimalist® Drop Point Fixed Blade Knife, model 2384K. It is a compact fixed blade outdoor survival knife. The knife features a high carbon stainless steel blade of just over two inches with a black stonewash finish and a scaled G10 handle with contoured finger grooves. It comes with a thermoplastic sheath with mounting options to allow the knife to be carried on a belt, attached to gear, or worn around the neck. The second is the Drifter Liner Lock Manual Folding Knife, model 6450K. It is an everyday carry folding pocket knife with a manually opened, locking blade. The knife features a high carbon stainless steel blade of nearly three inches with a titanium nitride finish and a scaled G10 handle. Once opened, the blade is held in place by an internal linerlock that can be disengaged with one hand to close the knife. It includes a pocket clip to allow the knife to be carried in a pocket when not in use. The third is the Ignitor® Assisted Opening Knife, model 6885. It is a folding pocket knife with an assisted-opening, locking blade. The knife has a 3.5-inch high carbon stainless steel drop point blade that is coated for corrosion resistance and a black scaled G10 handle. The blade features oversized, scalloped serrations along a portion of the cutting edge which are intended to improve performance when cutting fibrous materials such as rope, straps, or similar line. The blade deployment is manually initiated by the user pulling on the flipper tab and then deployed to the fully open position by the assisted opening mechanism. We note that your correspondence indicates this knife uses the same “OutBurst” assisted-opening mechanism addressed in Headquarters ruling W116730, dated November 7, 2006, which determined those knives were not considered switchblades and would be permitted unrestricted entry into the United States. Once opened, the blade is held in place by an internal linerlock that can be disengaged with one hand to close the knife. It is equipped with a pocket clip that permits carriage inside a pocket when not in use. The production process involves two countries. In Vietnam, stainless steel sheet from China is transformed into dimensionally final, model-specific knife blade blanks through laser cutting, surface grinding, and flattening to the knife’s final thickness. These blanks are then sent to China where they undergo deburring, punch removal of the handling loops, heat treatment, sharpening, surface finishing, and mechanical assembly with the handle components. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (HQ) 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 order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. We find the knife blade blanks provide the basic nature to these knives and that they are not substantially transformed to become a new article having a new name, character, or use after being further processed in China. As such, we hold the opinion that the country of origin for the Minimalist®, Drifter, and Ignitor® knives would be 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 CBP Regulations (19 CFR 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 Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division