The country of origin of a fixed blade knife.

N350389
July 9, 2025
OT:RR:NC:N4:415
CATEGORY: Origin Kristina M. Barry GDLSK, LLP 599 Lexington Avenue New York, NY 10022 RE: The country of origin of a fixed blade knife. Dear Ms. Barry: In your letter dated June 18, 2025, you requested a country of origin ruling on a serrated knife on behalf of your client, Lifetime Brands, Inc. The product under consideration is a fixed blade knife with a serrated cutting edge. The knives will be made from high-carbon, stainless steel and feature triple rivet accents on the handles. Your submission indicates that the raw steel panels will be cut to the form, shape, and size of the knife blade and would be produced in either Puerto Rico, Cambodia, Vietnam, or Malaysia. Further, you state that when knife blanks produced in either Puerto Rico, Cambodia, Vietnam, or Malaysia are sent to China for further processing, they “will be in the final form, size, and shape of the finished knife blades” and would leave in the same state regardless of the source country. In China, these knife blanks will be heat treated. The handles, made from either injection molded plastic or stamped metal that is welded over the end, will then be added to the knives. The handles of the blade are then ground to their final shape. Next, the knife edges are cut, and finally, the finished knives are cleaned, polished, inspected, and packaged for export to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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 order to determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and manufacturing

processes that these components undergo are considered in order to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. We find that the knife blanks hold the essential identity of the finished knives and that they are not substantially transformed to become new articles having a new name, character, or use after being further processed in China. As such, we hold the opinion that the country of origin for this serrated knife would be the source country of either Puerto Rico, Cambodia, Vietnam, or Malaysia. As these knives may be of Puerto Rican origin, please note that whether an article may be marked with the phrase "Made in the USA" or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (“FTC”). We suggest that you contact the FTC Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of proposed markings indicating that an article is made in the USA. 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 CBP Regulations (19 CFR 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 Kristopher Burton at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division