RE: The country of origin of pneumatic die grinder kits

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365619 October 14, 2026 OT:RR:NC:N1:164 CATEGORY: Origin Icey Huang Autowin Group Limited Flat/RM 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The country of origin of pneumatic die grinder kits Dear Icey Huang: In your letter dated October 1, 2026, you requested a country of origin ruling on pneumatic die grinder kits. Product information was submitted with your request. The items under consideration are two models of pneumatic die grinder kits for industrial polishing and grinding applications. During operation, compressed air enters the tool and is directed to a cylinder which houses a rotor. The highly compressed air forces the rotor to spin at high speed. The generated rotation is transferred to a connected spindle, collet or chuck, and finally the shank of an attached grinding tool. Item number 1151200007, described as a pneumatic angle die grinder with a red anodized aluminum housing, features a 90-degree head, a 6.3 millimeter (mm) to 3 mm reducing collet, and a speed rating of 20,000 rotations per minute. Item number 1151200008, described as a pneumatic straight die grinder with a black anodized aluminum housing and red end caps, features a 1/4-inch collet and a speed rating of 22,000 rotations per minute. Each die grinder will be packaged as a kit for retail sale with 10 mounted grinding points and two wrenches in a blow-molded plastic tool case. You confirmed that the wrenches are used to fasten the chucks around the shank of a grinding point attachment. As you described, the impact wrench is assembled in Malaysia from Malaysian and Chinese components. In Malaysia, metal stock and rough metal blanks from China undergo CNC machining such as turning, facing, milling, drilling, tapping, and deburring to obtain the form of the finished housing, rotor, cylinder, work spindle, and air inlet fitting. With regard to the housing, aluminum block sourced from Malaysia is die-cast to shape prior to CNC machining. These processes deliver the precise shapes, dimensions, splining, drilled holes, threading, slots, and surfaces which the components rely on for functioning. The rotor also undergoes heat treatment to achieve specified hardness and mechanical properties. Additionally, several Chinese-origin components are imported to Malaysia ready for assembly or consolidation into the kits without further processing. These components include, but are not limited to, the trigger levers, valve stems, rotor blades, plates, springs, mounted grinding points, pins, bushings, and bearings. Assembly of the angled die grinder (Item number 1151200007) begins with the installation of the muffle and air inlet into the aluminum housing. Following that, the valve stem is installed into the bushing and that subassembly is installed into the housing. A spring, the air regulator, the locking plug, a bearing, and the end plate are then installed to the housing. At that point, the rotor blades, front plate, and angle gear are installed to the rotor. The clamp nut is installed to the housing for installation of the clamp plant and angle head. In the following steps, a bearing, the clamp plate, the work spindle, the chuck, and the collet nut are sequentially installed to the angle head. The trigger lever is then installed to the housing to finish the assembly process. Finally, the angle die grinder is tested and packed with the loose accessories for export. Assembly of the straight die grinder (Item number 1151200008) begins with the installation of the plastic base and air inlet into the aluminum housing. After that, the spring is installed into the valve stem, and the valve stem and spring are installed into the air regulator. In the next steps, the valve stem, spring, and air regulator subassembly is installed into the housing, and a locking plug is installed. The rotor blades and the end plate with a bearing is installed to the rotor. At that point, the rotor is installed into the cylinder, and a rotor busing, front plate, and bearing are installed. The rotor and work spindle are then installed into the aluminum housing. The chuck is installed to the work spindle, and the clamp plate and cap are installed to the housing. In addition, the collet nut is installed into the work spindle, the trigger lever is installed to the housing with a pin, and a bushing is installed into the pin. Finally, the straight die grinder is tested and packed with the loose accessories for export. 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). According to the CBP website under Section 301 Trade Remedies Frequently Asked Questions, “When importing goods put up in sets for retail sale (in accordance with General Rule of Interpretation (GRI) 3) that contain articles subject to the Section 301 remedy, if the product that imparts the essential character to the set (i.e., the Harmonized Tariff Schedule of the United States (HTSUS) provision under which the entire set is classified) is covered by the Section 301 remedy, then the entire set will be subject to the additional 25 percent duties. If the HTSUS provision under which the entire set is classified is not covered by the Section 301 remedies, but the set contains components that are classified in a subheading covered by the 301 list, the 301 duties will not be assessed on the individual components.” The Harmonized Commodity Description and Coding System Explanatory Notes constitute the official interpretation of the HTSUS. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127 (August 23, 1989). Explanatory Note X to GRI 3(b) provides that the term “goods put up in sets for retail sale” means goods that: (a) consist of at least two different articles which are, prima facie, classifiable in different headings; (b) consist of articles put up together to meet a particular need or carry out a specific activity; and (c) are put up in a manner suitable for sale directly to users without re-packing. Goods classifiable under GRI 3(b) are classified as if they consisted of the material or component which gives them their essential character, which may be determined by the nature of the material or component, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the article. In this case, the pneumatic die grinder kits satisfy the criteria of goods put up in sets for retail sale according to GRI 3(b). As you described, the die grinder tools are the most technologically complex, expensive, and functionally integral product. Furthermore, they generate the high-speed rotation which the grinding attachments rely on, and the wrenches are accessories which are necessary for safe and effective polishing and grinding. Pursuant to GRI 3(b), the pneumatic die grinder tools impart the essential character of the pneumatic die grinder kits. Based on the submission, the Chinese-origin components are not identifiable as pneumatic die grinders at the time they are imported to Malaysia. The metal stock and rough blanks from China undergo significant and functionally transformative machining in Malaysia to become identifiable parts of a handheld power tool. The balance of loose components from China are less significant parts which are fundamentally dependent on the processing in Malaysia to become die grinders. In conclusion, the totality of manufacturing and assembly operations in Malaysia effect a substantial transformation of the components into a product with a new name, character, and use different from that possessed prior to processing. Accordingly, the country of origin of the pneumatic die grinders and pneumatic die grinder kits is Malaysia. 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