The country of origin of a Pick & Hook Set

N362465 July 6, 2026 OT:RR:NC:N1:118 CATEGORY: Origin Ling Tang Zhejiang Feiling Tools Co., Ltd. No.18 Huangliyang Industrial Estate Jiande 311600 China RE: The country of origin of a Pick & Hook Set Dear Mr. Tang: In your submission dated June 22, 2026, you requested a country of origin ruling for purposes of Section 301 duties, other tariffs and marking. Pictures and descriptions of the manufacturing processes were included in your submission. The item under consideration is identified as a Pick & Hook Set, SKU# 48-22-9215. The set consists of four tools, each with a metal shaft with a specially shaped tip attached to a plastic handle. These hand-operated tools are used for manual mechanical work, mainly to remove, pull, or position small parts such as O-rings, seals, clips, springs, and similar components in tight spaces. The user selects a hook or pick-shaped tool, inserts the tip into or around the part, and applies manual force through the handle to move or remove the component. The manufacturing process for each tool is identical. It begins in Thailand, where Chinese-origin steel coil is straightened to ensure uniform flatness and is cut to the required lengths of the shaft. The cut steel piece undergoes precision machining operations to form the functional geometry of the tool shaft. This includes shaping one end of the shaft into a specific hook, angle, or pick profile that is required for functional engagement with components. The shaft is further knurled to create textured patterns in order to improve grip retention and prevent slipping during use. The other end of the shaft is mechanically pressed to form the side wings that will attach to the plastic handle. The working end of the shaft is subsequently bent to the specific angle (e.g., 45°, 90°) to enable access into confined or obstructed spaces. The shaft is further shaped to ensure uniform diameter transitions and ergonomic geometry. The shaft is then sent to China where it is heat treated, electroplated, and assembled with a Chinese-origin injection-molded plastic handle. 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 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 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. Regarding the Pick & Hook Set, it is our view that steel coil is substantially transformed in Thailand into the fully formed shaft section of each tool in the set. This consists of its final functional shape with the specific hook, angle, or pick profile that is required for functional engagement with components. It is this shaft that contributes to the main functionality of the finished tool. Although not ready for immediate use, the shaft that arrives in China has a pre-determined use and is in a dedicated physical form of a pick or hook. It is therefore our opinion that the country of origin of each finished tool in the finished Pick & Hook Set, SKU# 48-22-9215, is Thailand. 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