The tariff classification and country of origin of a tool set

N362933
August 3, 2026
CLA-2-82:OT:RR:NC:N1:118
CATEGORY: Classification; Origin
TARIFF NO.: 8206.00.0000 / 8211.93.0035
Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The tariff classification and country of origin of a tool set Dear Ms. Jin: In your letter dated July 8, 2026, you requested a tariff classification and country of origin determination for purposes of Section 301 and other duties. Pictures and descriptions of the merchandise were included in your submission. The merchandise is described as a Paint Tool Set (item number GST0411), which includes the following steel tools: 1PC 3-inch Scraper (Made in Vietnam) 1PC 4-inch Putty Knife (Made in Vietnam) 1PC 12-inch Tape Knife (Made in Vietnam) 1PC 5-inch Jab Saw (Made in Vietnam) 1PC Utility knife (Made in China) You have stated that the tools will be packaged in China for shipment directly to the United States, with no additional processing or additions upon importation. The pictures you submitted indicate that the tools will be packaged for retail sale at the time of importation. Classification The applicable subheading for the Paint Tool Set (item number GST0411), will be 8206.00.0000, Harmonized Tariff Schedule of the United States (HTSUS) which provides for tools of two or more of headings of 8202 to 8205, put up in sets for retail sale. Heading 8206 requires that duty be applied to that article in the set subject to the highest rate of duty. The article in this set subject to the highest rate of duty (calculated at its ad valorem equivalency rate) is the utility knife, classifiable in subheading 8211.93.0035, HTSUS, which provides for knives with cutting blades, serrated or not (including pruning knives), other than

knives of heading 8208, and blades and other base metal parts thereof: other: knives having other than fixed blades: pen knives, pocket knives and other knives which have folding blades. The general rate of duty for the entire set will be 3 cents each plus 5.4 percent ad valorem. The complete classification of the set will be 8206.00.0000 / 8211.93.0035. Country of Origin 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). As your product is considered a General Rule of Interpretation (GRI) 1 tool set classifiable under heading 8206, HTSUS, we hold the opinion that the country of origin is provided by the source country of the majority of the tools that are classified within headings 8202 through 8205, which is Vietnam. See N360759, issued to your company on May 5, 2026. These tools do not lose their identity or character when they are packaged in China with the Chinese-origin utility knife. Therefore, the country of origin of the Paint Tool Set (item number GST0411) is Vietnam. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. 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