N355028

N355028 November 6, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn, LLP 303 E. Wacker Drive, Ste. 305 Chicago, IL 60601 RE: The country of origin of a socket, bit socket, impact socket, and socket sets Dear Mr. Friedman: In your letter dated October 20, 2025, on behalf of your client, Apex Tool Group, you requested a country of origin determination for purposes of Section 301 and IEEPA duties. Pictures of the items in different stages of manufacture were included with your submission, along with narratives of the manufacturing processes. The items under consideration are identified as a 1/4" shallow socket 5.5 mm, a socket set, a 3/8" bit socket 12 mm, a bit socket set, and a 1/2" impact socket 11/16". The socket set and bit socket set will include various sizes of the shallow sockets and bit sockets. A shallow socket, also known as a standard socket, is a tool with a low profile that is designed to fit in tight spaces with limited overhead clearance. It is used to work on nuts and bolts that do not have long, exposed threads, providing a secure grip on shorter fasteners. A bit socket is comprised of a bit holder socket with a press-fit bit. One end of the bit socket has a permanently attached bit (e.g., flat head, Philips head, Torx, etc.) that is used to turn a screw head. The other end has a drive that allows the bit socket to be attached to a screwdriver handle, ratchet handle, or power (electric or pneumatic) drill. An impact socket is similar to a standard socket except it is designed for use with high-torque power tools like impact wrenches and is built to withstand intense force and vibration without breaking. You have stated that the manufacturing process for the shallow socket and the socket set are the same. It begins in Vietnam, where Chinese-origin steel bar in coils is cold forged into the approximate circumference and length of a finished socket. The socket blank is then sent to China, where it is further machined, and in some cases, a knurled band and logo is also machined into the socket. The socket is then heat-treated and plated for appearance. The bit socket is manufactured with a bit that is purchased from a supplier that produces it in Thailand. The socket holder is cold forged from steel in China, further machined, and then the Thai bit is press-fit into the socket holder. You have stated that the same manufacturing scenario applies to the the bit socket set. The impact socket is manufactured in the same manner as the shallow socket. Steel blanks are cold forged in Vietnam into the approximate circumference and length of the finished impact socket. The blanks are then sent to China for finishing, which includes drilling a hole for a pin used to fix the socket to a toolholder, machining the outer diameter to size, knurling, and marking with size. After machining, the impact socket is subject to heat treatment, vibration grinding, polishing, oxidation, and packaging. When determining the country of origin for purposes of applying current trade remedies under Section 301 and other 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 regard to the shallow socket and impact socket, it is our view that raw steel is substantially transformed in Vietnam into recognizable tool blanks. Based on the submitted information and pictures of the shallow socket and impact socket, it is our opinion that no article emerges from the finishing operations in China with a new name, character, or use different from that prior to processing. Although not ready for direct use, the tool blanks that arrive in China have a pre-determined use and are in a dedicated physical form of sockets. Therefore, it is our determination that the country of origin of the 1/4" shallow socket 5.5 mm, socket set, and 1/2" impact socket 11/16" is Vietnam. Regarding the bit socket, our office notes that the tool is comprised of two main components, i.e., a bit holder socket and a bit. The bit holder socket allows for attachment to a handle or power tool for more torque. In this particular case, we view that as an extension of the function and force of the bit. The permanent attachment of the bit allows a user to apply more force than a replaceable bit. The bit is more durable because of this as well. It is therefore our opinion that the bit, manufactured in Thailand, provides the essential characteristic of the finished bit socket. Accordingly, the county of origin for the 3/8" bit socket 12 mm and the bit socket set 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 anthony.e.grossi@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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 regard to the shallow socket and impact socket, it is our view that raw steel is substantially transformed in Vietnam into recognizable tool blanks. Based on the submitted information and pictures of the shallow socket and impact socket, it is our opinion that no article emerges from the finishing operations in China with a new name, character, or use different from that prior to processing. Although not ready for direct use, the tool blanks that arrive in China have a pre-determined use and are in a dedicated physical form of sockets. Therefore, it is our determination that the country of origin of the 1/4" shallow socket 5.5 mm, socket set, and 1/2" impact socket 11/16" is Vietnam. Regarding the bit socket, our office notes that the tool is comprised of two main components, i.e., a bit holder socket and a bit. The bit holder socket allows for attachment to a handle or power tool for more torque. In this particular case, we view that as an extension of the function and force of the bit. The permanent attachment of the bit allows a user to apply more force than a replaceable bit. The bit is more durable because of this as well. It is therefore our opinion that the bit, manufactured in Thailand, provides the essential characteristic of the finished bit socket. Accordingly, the county of origin for the 3/8" bit socket 12 mm and the bit socket set is Thailand. The holding set forth above applies only to the specific factual sit