RE: The country of origin of a pneumatic ratchet wrench

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 N365621 October 20, 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 a pneumatic ratchet wrench Dear Icey Huang: In your letter dated October 1, 2026, you requested a country of origin ruling on a pneumatic ratchet wrench. Product information was submitted with your request. The item under consideration is a pneumatic ratchet wrench (Item number 1151200011) to tighten and loosen nuts and bolts for automotive and industrial assembly work. The ratchet wrench features a 1/2-inch square drive anvil, single ratchet pawl head, reversible direction, and quick connect plug. You state that the ratchet wrench is capable of delivering 150 rotations per minute (free speed) and a max torque of 61 Newton-meters (45 foot-pounds). During operation, the user applies pressure to the lever which allows compressed air to enter the tool. The compressed air is precisely channeled by the cylinder housing to push against rotor vanes. This action provides the primary rotational power which is transferred to the wrench’s anvil. The single-pawl ratchet mechanism allows for rotation in one direction while preventing motion in the reverse direction. As you described, the ratchet wrench is assembled in Malaysia from Malaysian and Chinese components. In Malaysia, rough metal blanks and bar stock from China undergoes CNC machining such as drilling, threading, turning, boring, grinding, and deburring to obtain the form of the finished cylinder housing, ratchet housing, and quick-connect plug. With regard to the wrench housing, aluminum ingots sourced from Malaysia are die-cast to shape prior to CNC machining. These processes deliver the precise shapes, dimensions, drilled holes, threading, and surfaces which the components rely on for functioning. All Malaysian-manufactured parts undergo testing for performance and inspection for quality. Additionally, several Chinese-origin components are imported to Malaysia ready for assembly without further processing. These components include, but are not limited to, the rotor, the rotor vanes, the ratchet anvil assembly, the ratchet yoke, the crank shaft, the valve stem, valve plugs, end plates, bearings, and gears. Final assembly of the ratchet wrench begins with the installation of the valve seat fitting and valve plug onto the wrench housing. After that, the rear bearing is installed to the rear end plate. The rear end plate, rotor vanes, cylinder housing, front end plate, and front bearing are installed into and onto the rotor. Following that, the cylinder housing containing the rotor and other components is installed into the housing. A ring gear is then installed onto the housing, and an idler gear is installed onto the idler gear shaft. At that point, the idler gear shaft, clamp nut, and ratchet housing are installed onto the wrench housing. The drive bushing is installed onto the crank shaft which is installed into the rachet housing. In the next steps, the ratchet yoke and ratchet anvil assembly are assembled onto the ratchet housing. Assembly finishes with the installation of the lever, pin, and air inlet with quick-connect plug onto the wrench housing. Finally, the completed ratchet wrench is tested for function and accuracy and packed in a box for export to the United States. 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 the scenario you described, there is an abundance of Chinese items which are exported to Malaysia as finished, identifiable, and pre-determined components of a pneumatic wrench. These components include, but are not limited to, the rotor and rotor vanes, the ratchet anvil assembly, and the ratchet yoke. They possess the final shapes, surfaces, and functionality that are dedicated for use as components of a pneumatic wrench and require no additional manufacturing. In Malaysia, they are manually assembled with other Chinese and Malaysian components to form a completed pneumatic wrench. Based on the submitted information, the manufacturing of the wrench housing, cylinder housing, ratchet housing, and quick-connect plug in Malaysia is notable. However, the totality of operations in Malaysia does not effect a substantial transformation of the finished, identifiable, and functionally pre-determined components from China into a product with a new name, character and use different than that possessed prior to processing. Accordingly, the country of origin of the pneumatic ratchet wrench 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 (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