RE: The country of origin of a pneumatic impact wrench

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365620 October 9, 2026 OT:RR:NC:N1:164 CATEGORY: Origin Icey Huang Autowin Group Limited Flat/RM 08, 15/F Witty Commercial Building 1A-1L Tung Choi Street Mongkok, Kowloon, Hong Kong China RE: The country of origin of a pneumatic impact wrench Dear Icey Huang: In your letter dated October 1, 2026, you requested a country of origin ruling on a pneumatic impact wrench. Product information was submitted with your request. The item under consideration is a pneumatic impact wrench (Item Number 1151200009) to tighten and loosen nuts and bolts for automobile tire maintenance and industrial assembly. The impact wrench features a 1/2-inch square drive anvil, twin hammer impact mechanism, reversible direction, and a quick-connect plug. You state that the impact wrench is capable of delivering up to 1000-1200 Newton-meters of torque at 8,500 rotations per minute. During operation, the user applies pressure to the trigger which allows compressed air to enter the tool. The compressed air pushes against rotor blades which forces the rotor to spin at high speeds. This action provides the primary rotational power which is transferred to the wrench’s anvil. As the wrench encounters resistance from a nut or bolt, its hammer mechanism strikes the anvil with powerful impacts to increase torque output and overcome the resistance. As you described, the impact wrench is assembled in Malaysia from Malaysian and Chinese components. In Malaysia, rough metal blanks from China undergo CNC machining such as milling, drilling, boring, grinding, grooving, and deburring to obtain the form of the finished anvil, hammer cage, cylinder, and rotor. These processes deliver the precise shapes, dimensions, splining, drilled holes, slots, and surfaces which the components rely on for functioning. The anvil, hammer cage, and rotor also undergo heat treatment to achieve specified hardness and mechanical properties. Also in Malaysia, plastic pellets sourced from China undergo injection molding and over-molding to form the wrench’s plastic housing and grip. All Malaysian-manufactured parts undergo testing for performance and inspection for quality.
Additionally, several Chinese-origin components are imported to Malaysia ready for assembly without further processing. These components include, but are not limited to, the aluminum housing cover, the hammers, the rotor blades, the trigger, the quick-connect plug, the reversing button, gasket, bearings, pins, springs, screw rods and O-rings. Final assembly of the impact wrench begins with the installation of the hammer, hammer pin, and anvil into the hammer cage. The twin hammer impact assembly is installed into the housing cover, and a bearing is installed onto the front cover. The rotor blades are installed into the rotor, and the rotor is then installed into the cylinder. After that, the front cover and rotor cover are installed onto the cylinder. The reversing button is installed on the rear cover which is fastened with screws. In the next steps, the cylinder is installed into the housing, the housing cover assembly is installed to the motor housing assembly, and the trigger is installed. Following that, a compressed spring is installed onto the intake valve, an exhaust cover is installed onto the air inlet, and an O-ring is installed. The intake valve and air inlet are installed into the main housing and the quick connect plug is installed onto the air inlet. Finally, the completed impact wrench undergoes testing and packaging. 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). In the scenario you described, the Chinese-origin components are not identifiable as an impact wrench when they are imported to Malaysia. The rough blanks and plastic pellets from China undergo significant and functionally transformative machining and molding processes in Malaysia to become identifiable parts of a handheld power tool. The balance of loose components from China are of less significance and are fundamentally dependent on the processing in Malaysia to become an impact wrench. In conclusion, the totality of manufacturing and assembly operations in Malaysia effect a substantial transformation of the components into a product with a new name, character, and use different from that possessed prior to processing. Accordingly, the country of origin of the pneumatic impact wrench is Malaysia. 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 (C.F.R.), 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 C.F.R. 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 Paul Taylor at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division