N355067

N355067 November 10, 2025 CLA-2-84:OT:RR:NC:N1:164 CATEGORY: Classification; Origin TARIFF NO.: 8466.10.0175; 9903.02.69 Fay Jin Great Star Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The tariff classification and country of origin of a tool set, and the country of origin of a separately imported ratchet handle and a separately imported extension bit holder Dear Fay Jin: In your letter dated October 21, 2025, you requested a tariff classification and country of origin ruling regarding a tool set, and a country of origin ruling regarding a ratchet handle and an extension bit holder. Product information was submitted with your request. The tool set under consideration is described as a 40-piece tool set designed for use in automotive, mechanical, home repair, and construction projects to apply a certain amount of torque to fasteners such as nuts and bolts to ensure they are tightened to specification. The submitted material displays the ratchet handle set up in various configurations to accommodate a user’s spatial constraints and torque transmission needs. All configurations feature the ratchet handle as a hub to hold the extension bars and bits vertically and horizontally during use. In your submission, you state that the components are packed in China ready for retail sale after importation into the United States. The tool set consists of the following items in two sourcing scenarios: Scenario 1 1 - Ratchet handle (Vietnam) 3 - Extension bit holders (Vietnam) 28 - Short bits (China) 8 - Long bits (China) Scenario 2 1 - Ratchet handle (Vietnam) 3 - Extension bit holders (China) 28 - Short bits (China) 8 - Long bits (China) The ratchet handle under consideration is designed to transmit torque while limiting motion in one direction. This quality eliminates the need to repeatedly remove the handle from the fastener during use. Based on the submitted information, the ratchet mechanism is seated in a central housing with two arms extending laterally. Both the ratchet mechanism and lateral arms feature female hexagonal mating surfaces to securely connect to the male hexagonal ends of other items such as detachable extension bars and bits. The ratchet handle measures 2.56 inches in length by .945 inches in width by .634 inches in height and weighs 1.01 ounces. The ratchet handle manufacturing process begins in Vietnam where globally sourced aluminum is die-cast to the final size and shape of the finished ratchet handle. It is then shipped to China where it undergoes machining such as milling and turning operations to achieve precise dimensions and surface quality. After that, the handle undergoes oxidation coating to enhance corrosion resistance and aesthetic quality. Finally, the ratchet handle is assembled with several Chinese-origin components including a drive tang, a magnet, a shifting tooth, a selector knob, a retaining ring, a steel ball, a spring, a cover plate, a wire retaining ring, and a screw. The extension bit holder under consideration consists of a bit holder on one end and a hexagonal (hex) rod on the other. The bit holder is made of aluminum alloy, and the hex rod is made of carbon steel. The two ends facilitate connection to and between other items such as ratchet handles and bits. Manufacturing of the extension bit holder begins in Vietnam where aluminum is extruded to form the interior hexagonal shape and cut to the size of the finished bit holder. At that point, it is shipped to China where it undergoes machining such as chamfering to enhance the alignment and connection to bits. After machining, the bit holder undergoes oxidation coating to enhance corrosion resistance and aesthetic quality. Finally, the bit holder is assembled with Chinese-origin components such as a hex rod, a sleeve, and a magnet. Classification Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in accordance with the General Rules of Interpretation (GRIs). GRI 1, HTSUS, states in part that for legal purposes, classification shall be determined according to the terms of the headings, any relative section or chapter notes and, unless otherwise required, according to the remaining GRIs taken in order. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3. The instant tool sets consist of at least two different articles that are, prima facie, classifiable in different headings. They consist of articles put up together to carry out a specific activity (i.e., automotive, mechanical, home repair, and construction). Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the set in question is within the term “goods put up in sets for retail sale.” GRI 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. Here, the ratchet handle is the central attachment point and mechanism for the extension bit holders and bits. Without the ratchet handle to provide ratcheting and torque transmission, the practical usefulness of the extension bit holders and bits is significantly hampered because the ability to deliver torque to fasteners is substantially harmed. Since the overall functionality of the set is largely dependent on the mechanical capabilities and unique physical features of the ratchet handle, it is the component which gives the tool set its essential character. As a result, the tool set will be classified based on the ratchet handles. The applicable subheading for the 40-piece tool set will be 8466.10.0175, HTSUS, which provides for “Parts and accessories suitable for use principally with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for the machines; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Other.” The general rate of duty will be 3.9 percent ad valorem. Country of Origin When determining the country of origin, 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). According to the CBP website under Section 301 Trade Remedies Frequently Asked Questions, “When importing goods put up in sets for retail sale (in accordance with General Rule of Interpretation 3) that contain articles subject to the Section 301 remedy, if the product that imparts the essential character to the set (i.e., the HTSUS provision under which the entire set is classified) is covered by the Section 301 remedy, then the entire set will be subject to the additional duties. If the HTSUS provision under which the entire set is classified is not covered by the Section 301 remedies, but the set contains components that are classified in a subheading covered by the 301 list, the 301 duties will not be assessed on the individual components.” In the tool set sourcing scenarios, the ratchet handle of Vietnamese origin imparts the essential character per GRI 3 and thus controls the classification and country of origin of each set. Accordingly, the country of origin of the tool set in both scenarios is Vietnam. Regarding the separately imported ratchet handle, your submission states that the handle is die-cast to the size and shape of the finished ratchet handle in Vietnam. In China, 

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). According to the CBP website under Section 301 Trade Remedies Frequently Asked Questions, “When importing goods put up in sets for retail sale (in accordance with General Rule of Interpretation 3) that contain articles subject to the Section 301 remedy, if the product that imparts the essential character to the set (i.e., the HTSUS provision under which the entire set is classified) is covered by the Section 301 remedy, then the entire set will be subject to the additional duties. If the HTSUS provision under which the entire set is classified is not covered by the Section 301 remedies, but the set contains components that are classified in a subheading covered by the 301 list, the 301 duties will not be assessed on the individual components.” In the tool set sourcing scenarios, the ratchet handle of Vietnamese origin imparts the essential character per GRI 3 and thus controls the classification and country of origin of each set. Accordingly, the country of origin of the tool set in both scenarios is Vietnam. Regarding the separately imported ratchet handle, your submission states that the handle is die-cast to the size and shape of the finished ratchet handle in Vietnam. In China, the die-cast aluminum ratchet handle undergoes machining, surface treatment, and assembly with Chinese-origin components to complete the ratchet mechanism. Based on the information provided, the die-cast ratchet handle manufactured in Vietnam is expo