The country of origin of origin of a basin wrench

N363856
August 4, 2026
OT:RR:NC:N1:118
CATEGORY: Origin Eric Lee Zhangjiagang Tianhua Hardware Co., Ltd. Xinle Rd., Daxin Town, Jiangsu Province Zhangjiagang 215636 China RE: The country of origin of origin of a basin wrench Dear Mr. Lee: In your letter dated July 30, 2026, you requested a country of origin determination for purposes of Section 301, other duties and marking. Pictures and descriptions of the manufacturing processes were included in your submission The product under consideration is a basin wrench. It is a plumbing tool used in confined spaces, such as underneath kitchen and bath sinks, to turn fasteners and pipes. The tool consists of an extendable shaft that is attached to a lower jaw. The metal shaft is made of steel and is comprised of two pieces, one inside the other, that slide out to extend the reach of the wrench. The inner part of the shaft attaches to the lower jaw with a pivot pin. The pivot pin enables the jaw assembly to rotate around its axis perpendicular to the shaft. A spring-loaded curved jaw is attached to the lower jaw with an additional pivot pin. Both jaws incorporate teeth for better gripping power. A handle fits through a hole at the other end of the extendable shaft. You have stated that the basin wrench will be produced in Thailand and China. In Thailand, raw steel rods are drop forged to make the jaw blanks of the lower jaw and curved jaw. The inner piece of the extendable shaft is also made in Thailand from raw steel stock. These three components are further die-cut, deburred, and sandblasted before being sent to China. Upon arrival in China, the jaws are machined to add teeth, holes are drilled in each piece, and all components are heat treated. The Thailand-origin inner shaft is then assembled with a Chinese-origin outer shaft piece. The jaws and extendable shaft are further assembled with Chinese-origin springs, pins, clips, and a handle. Finally, the completed basin wrench is packaged for retail sale and exported to the United States. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding the finished basin wrench, we find that the processes and assembly operations performed in China do not constitute a substantial transformation of the three main components of the tool (i.e., the two jaw blanks and inner shaft) that are manufactured in Thailand. These articles provide the principal characteristics of the finished basin wrench, are dedicated for use as such, and cannot be used for any other purpose. The character of the jaw blanks and inner shaft remains unchanged after the machining, drilling of holes, and heat treatment that occurs in China. We also note that the inner shaft is the part that attaches to the lower jaw upon final assembly and is consequently essential to the tool’s operation. Therefore, it is the opinion of our office that the country of origin of the finished basin 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 P. Forkan Director National Commodity Specialist Division