The country of origin of pliers

N355864
November 25, 2025
OT:RR:NC:N1:118
CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn LLP 303 East Wacker Drive, Suite 305 Chicago, IL 60601 RE: The country of origin of pliers Dear Mr. Friedman: In your letter dated November 7, 2025, on behalf of your client, Apex Tool Group, you requested a country of origin determination for purposes of Section 301 and IEEPA duties. Pictures of the items in different stages of manufacture were included with your submission, along with narratives of the manufacturing processes. The items under consideration are two types of pliers, identified as 6 ½" diagonal pliers and 10" tongue & groove pliers. Diagonal pliers have angled jaws for clean, accurate wire cutting. Tongue & groove pliers are adjustable and designed to grip and turn objects of different sizes. You have stated that the manufacturing process for both pliers is identical. The manufacturing process begins in Thailand, where Chinese-origin steel is cut and then forged into the shape and form of the two halves of the pliers (i.e., the pieces incorporating the handles and jaws). These pieces are sent to China where the jaws are milled with teeth, the grooved joints are machined, and the pivot holes are punched. The pieces are then manually aligned and riveted together to create a pivot. The pliers are further heat treated, polished, and coated. Finally, the handles are dipped in plastic for a comfort grip, and the finished pliers are 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 country of origin of the 6 ½" diagonal pliers and 10" tongue & groove pliers, it is our view that raw steel is substantially transformed in Thailand, where it is cut and forged into the shape and form of the

two halves of the pliers (i.e., the pieces incorporating the handles and jaws). These articles provide the principal characteristics and main functionality of the finished tools, are dedicated for use as such, and cannot be used for any other purpose. The character of these articles remains unchanged after the manufacturing processes and assembly operations that occur in China. Therefore, it is the opinion of our office that the country of origin of the 6 ½" diagonal pliers and 10" tongue & groove pliers 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division