The country of origin of an 18" Indexing Flat Pry Bar

N362606 July 22, 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 an 18" Indexing Flat Pry Bar Dear Ms. Jin: In your letter dated June 26, 2026, you requested a country of origin determination for 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 is identified as an 18" Indexing Flat Pry Bar. It is a hand tool constructed from carbon steel that is used for prying, lifting and separating materials, and removing nails. It is constructed with a rotatable claw-shaped head that can swivel 180 degrees and lock at 16 positions by pressing an indexing gear located on the side of the claw. The tool also incorporates a raised striking surface and narrow jab end to provide strong leverage for prying materials and pulling nails. The tool has a length of 18 inches and weighs 2.20 pounds. You propose two manufacturing scenarios. The first scenario begins in Vietnam, where carbon steel is forged into a flat rough shape of the claw head of the tool. This article is then sent to China, where it is further forged and bent into its final claw-shaped angle head of the pry bar. A V-shaped notch is machined into the claw for the nail puller slot and holes are drilled into it for assembly with the handle and an indexing gear. Teeth are then milled into one of the holes, to allow the indexing gear to swivel the head and lock it into position once assembled. Further in China, the metal handle is forged, drilled with assembly holes and milled with teeth for assembly with an indexing gear and the claw head. The handle and the claw also undergo quenching, tempering, sandblasting, and electrophoretic coating. Finally, the handle and claw are assembled with a Chinese origin indexing gear, end cap, spring, and plastic handle grip. The second manufacturing scenario is similar to the first, except a rough shape of the handle is forged in Vietnam. It is then sent to China, along with the flat rough shape of the claw head, where it is drilled with assembly holes and milled with teeth for assembly with a Chinese-origin indexing gear and the final claw shaped 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). In regard to your manufacturing scenarios, there is no dispute that the rough shapes of the claw head and handle, which are produced in Vietnam, are dedicated for use in the finished flat indexing pry bar. In other words, they have a pre-determined use at the time they are exported from Vietnam to China. However, while this is a consideration, as noted by the court in National Hand Tool, this does not preclude a finding of substantial transformation. Unlike the tools in National Hand Tool that were in the final form at the time they left Taiwan and were clearly recognizable by name, the rough shapes of the claw head and handle that leave Vietnam are not clearly recognizable as parts of a finished indexing flat pry bar. As the court stated in National Hand Tool, we must look at the totality of the evidence. We also must consider the product at issue, how it functions, and the purpose of the components within it carrying out its function. An indexing flat pry bar is designed to operate with a rotatable claw-shaped head that can swivel 180 degrees and lock at multiple positions by engaging an indexing gear located on the side of the claw. In both of your manufacturing scenarios, the claw head is further forged and bent into its final claw-shaped angle in China. Furthermore, both the claw head and the handle are milled with teeth in China for assembly with a Chinese-origin indexing gear and end cap. Therefore, the totality of the evidence leads our office to conclude that the country of origin of the finished 18" Indexing Pry Bar in both of your manufacturing scenarios is China. 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