The country of origin of a replacement blade

N362931
July 29, 2026
OT:RR:NC:N1:118
CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a replacement blade Dear Ms. Jin: In your letter dated July 7, 2026, you requested a country of origin determination for purposes of Section 301 and other duties. Pictures and descriptions of the merchandise and manufacturing process were included in your submission. The product under consideration is described as a separately sold replacement blade (model GS10104-1) designed exclusively for installation and use in a 13-inch multi-floor cutter. When installed in the cutter, the blade can cut different types of flooring materials, including laminate, engineered wood, and vinyl plank. The overall dimensions of the blade are 13.38 inches × 1.18 inches × 0.09 inches, and it weighs 0.45 pounds. The manufacturing process for the replacement blade begins in Vietnam, where raw steel is stamped into a blank with the overall size and shape of the finished blade, and the cutting edge is rough ground. The blank is then shipped to China where it is heat treated, punched with installation holes and the cutting edge is finely finished. 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). Our office reviewed the submitted manufacturing process for the replacement blade, and we are of the opinion that the blade blank holds the essential identity of the finished blade. The further processing in China does not substantially transform it into a new and different article of commerce. As such, the country of origin for the replacement blade (model GS10104-1) is Vietnam.

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 P. Forkan Director National Commodity Specialist Division