The country of origin of a flooring cutter

N362419 July 7, 2026 OT:RR:NC:N1:164 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a flooring cutter Dear Fay Jin: In your letter dated June 18, 2026, you requested a country of origin ruling on a flooring cutter. Product information was submitted with your request. The item under consideration is a 13-inch manually operated multi-flooring cutter (Model GS10104). As described, the item is a tool specially designed to cut various flooring panels using a lever-driven shearing action. The cutter is intended to be used for residential flooring installation, renovation, and do-it-yourself construction projects. During use, a flooring panel is positioned on the base plate and inserted between the blade (held by the blade holder) and the blade base. Once the panel is positioned, the user grips a handle at the end of a lengthy lever arm and pushes down, delivering the requisite mechanical force that actuates the downward motion of the blade to cut the flooring panel. You indicate it will be capable of cutting flooring materials of varying thickness such as laminate, engineered wood, fiber cement, and luxury vinyl tile and plank. Based on the submitted material, the flooring cutter features a base plate with feet and is designed to be placed on a flat surface during use. Furthermore, it will be imported as a standalone, manually operated tool without electric power or motor. Your submission suggests that the flooring cutter consists of four primary components: a steel blade, an aluminum blade holder, an aluminum blade base, and an aluminum lever handle. Additionally, 20 Chinese-origin components will be incorporated during final assembly processes in China to produce the finished flooring cutter. These Chinese components include, but are not limited to, a connecting rod, a guide rail, a rotary shaft, a limit block, an angle rod, a plastic base, and an aluminum support rod. For country of origin and marking purposes, you present three scenarios in which all components will be manufactured in Vietnam or China. In scenario one, steel from China or other countries is shipped to Vietnam where it undergoes blanking and preliminary edge grinding to produce a blade blank to the approximate size and shape of the finished blade. Similarly, aluminum raw materials are shipped to Vietnam where they undergo cutting to the size and shape of the blade holder. The blade holder blanks are then Computer Numerical Control (CNC) machined (e.g., drilling and milling) in Vietnam to produce the finished blade holder. In China, the blade blanks from Vietnam undergo heat treatment, hole punching, and additional edge grinding to produce the finished blade. Also in China, aluminum from China or other countries is cut to the approximate sizes and shapes of the blade base and lever handle and CNC machined to produce finished parts. Following that, the blade (blanked in Vietnam), blade holder (Vietnam), blade base (China), and lever handle (China) are assembled with 20 Chinese components by press fitting and fastening to produce the finished flooring cutter. Scenario two is the same as scenario one, except the blade base will also be manufactured in Vietnam. In scenario three, the blade blank, blade holder, blade base, and lever handle will all be manufactured in Vietnam. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (CBP) Regulations (19 C.F.R. 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 C.F.R. 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. In your submission, you specifically described the floor cutter as “lever-driven,” meaning that a user must apply force to an integrated lever handle to actuate and drive the downward shearing motion of the blade into the flooring material. We agree that the blade (and by extension its holder and base) is capable of “cutting,” in general, on its own. However, the flooring cutter at issue is more than just a cutting blade with an adjacent handle to grip (such as a knife). In fact, it is a more complex mechanical device which fundamentally relies on the force transmitted from a lever to operate as a machine. Without the lever handle, the flooring cutter would be functionally disabled because the blade would not receive the requisite force to cut the workpiece. The product was specifically designed to operate in this fashion, and without the lever, it would not be effectively or efficiently capable of doing so. Furthermore, the user has no alternative avenue for driving the cutting blade action. As such, the flooring cutter is functionally dependent on the lever handle for its intended operation. Consequently, it accounts for a significant portion of the product’s overall identity. Based on the totality of information, the Vietnamese blade, blade holder, and blade base in scenarios one and two undergo a substantial transformation during processes in China. Although the assembly in China is simple, the Vietnamese items do not obtain the qualities or functional identity of a manually operated, lever-driven flooring cutter until they are combined with the lever handle and the 20 Chinese components in China. At that point, the individual blade, blade holder, and blade base lose their individual identities and become a product with a new name, character, and use (Model GS10104). As a result, the country of origin in scenarios one and two will be China. In scenario three, the blade, blade holder, blade base, and lever handle are made in Vietnam. Collectively, these components directly interact with both the workpiece and the user to achieve the desired goal of cutting flooring panels. Since the critical functionality and product-specific identity of the lever handle are present prior to export from Vietnam, the four items are not substantially transformed by the processes in China. Accordingly, the country of origin in scenario three will 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at paul.m.taylor@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division