The country of origin of a combination wrench

N346315 March 12, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Faye Ding Jiangsu Homshrin Industrial Technology Co., Ltd No. 9, South Huanghai Road Jiangdu District, Yangzhou City Jiangsu Province, 225200China RE:  The country of origin of a combination wrench Dear Ms. Ding: In your letter dated February 26, 2025, you requested a country of origin determination on a combination wrench for purposes of Section 301 duties.  Descriptions and pictures of the manufacturing process were included in your submission. The production process for the combination wrench begins in Thailand, where the wrench body is forged from Chinese-origin steel bar into its general shape and size.  It is then trimmed and deburred.  The wrench blank is then shipped to China where holes are punched, and the open-end and box-end are machined.  The tool is further heat-treated, polished and electroplated.  Finally, the wrench is packaged and shipped to the United States. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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). Regarding the country of origin of the combination wrench, it is our view that the forging of the steel imparts the essential characteristics of the finished wrench.  In Thailand, the wrench is forged and takes on the general shape and size of the finished tool.  Based on the provided pictures and description of the finishing operations performed in China, the forged tool is not substantially changed so as to transform it into a new article with a different name, character or use. Therefore, it is the opinion of our office that the country of origin of the combination wrench 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 [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division