The country of origin of a 4-way lug wrench

N352719
August 25, 2025
OT:RR:NC:N1:118
CATEGORY: Origin Eric Lee Zhangjiagang Tianhua Hardware Co., Ltd. XinLe Rd., DaXing Town Zhangjiagang 215636 China RE: The country of origin of a 4-way lug wrench Dear Mr. Lee: In your letter dated August 21, 2025, you requested a country of origin determination for purposes of Section 301 and IEEPA duties. Pictures of the merchandise in different stages of manufacture were included with your submission, along with a narrative of the manufacturing processes. The item under consideration is identified as a 4-way lug wrench, also referred to as a cross wrench. It is a steel hand tool used to loosen, tighten, or remove lug nuts on wheels. The tool is designed in a cross-like shape with four different hexagonal socket sizes on its ends. The manufacturing process for the 4-way lug wrench begins in Thailand, where raw steel rods are drop-forged into the two cross bars of the wrench. This includes forming the hexagonal socket ends of each bar. The cross bars are then sent to China, where they are machined to precision and welded together at their center. Finally, the wrench is heat-treated, electroplated and packaged for retail sale. When determining the country of origin for purposes of applying current trade remedies under Section 301 and other 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). Regarding the 4-way lug wrench, it is our view that raw steel rods are substantially transformed in Thailand into the two cross bars of the wrench, along with the hexagonal socket ends. These cross bars and hexagonal sockets contribute to the main functionality of the finished wrench, which is attaching or removing lug nuts. Based on the provided descriptions and pictures of the additional processing and assembly operations performed in China, these components are not substantially changed so as to transform them into new articles

with a different name, character, or use. It is therefore the opinion of this office that the country of origin of the 4-way lug 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,
(for) James Forkan Acting Director National Commodity Specialist Division