N355710

N355710 November 10, 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 wrench set Dear Mr. Friedman: In your letter dated November 4, 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 merchandise under consideration is identified as an 18pc Socket Wrench Set, which includes one ratchet handle, one extension adaptor and sixteen sockets. The steel tools are used in conjunction with each other to turn nuts and bolts. The manufacturing process for the socket wrench set begins in Vietnam, where Chinese-origin steel is cold forged into blanks of the ratchet handle, extension adaptor and sockets. The pictures you submitted indicate that these blanks are in the approximate size and shape of the finished articles. These blanks are then sent to China for further finishing operations. The ratchet handle blank undergoes grinding, oil and cold-pressing, CNC machining, stamping, heat treating, burring, and chromium electroplating. Components are then assembled and installed into the ratchet handle’s circular head to complete the ratcheting mechanism. The socket blanks are ground, knurled, heat treated, and plated. A hole is drilled into the head of the extension blank, which enables it to be assembled with a steel ball detent. It is then heat treated, plated, stamped and the steel ball detent is pressed into the hole. This enables the finished extension adaptor to hold a socket. Finally, the finished ratchet handle, extension bar and sockets are packaged for retail sale. 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 determining the country of origin of the 18pc Socket Wrench Set, we must first establish the origin of the individual items within the set. With regard to the sockets and extension adaptor, it is our view that steel is substantially transformed in Vietnam into recognizable socket blanks and an extension blank. Based on the submitted information and pictures of the tools, 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 immediate use, the blanks that arrive in China have a pre-determined use and are in a dedicated physical form of sockets and an extension adaptor. It is therefore our opinion that the country of origin of the finished sockets and finished extension adaptor is Vietnam. In regard to the ratchet handle, the forged handle manufactured in Vietnam is exported to China with a pre-determined end use as a type of ratchet handle. Functionally, the forged handle and its circular head enable a user to grip and manually apply the force required to tighten fasteners. In totality, the processing and assembly operations in China do not substantially transform the forging from Vietnam. No article emerges from the operations in China with a new name, character, or use. Accordingly, the country of origin of the ratchet handle will be Vietnam. As we have determined that all articles in the set are of Vietnamese origin, the country of origin of the 18pc Socket Wrench Set is Vietnam. 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 determining the country of origin of the 18pc Socket Wrench Set, we must first establish the origin of the individual items within the set. With regard to the sockets and extension adaptor, it is our view that steel is substantially transformed in Vietnam into recognizable socket blanks and an extension blank. Based on the submitted information and pictures of the tools, 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 immediate use, the blanks that arrive in China have a pre-determined use and are in a dedicated physical form of sockets and an extension adaptor. It is therefore our opinion that the country of origin of the finished sockets and finished extension adaptor is Vietnam. In regard to the ratchet handle, the forged handle manufactured in Vietnam is exported to China with a pre-determined end use as a type of ratchet handle. Functionally, the forged handle and its circular head enable a user to grip and manually apply the force required to tighten fasteners. In totality, the processing and assembly operations in China do not substantially transform the forging from Vietnam. No article emerges from the operations in China with a new name, character, or use. Accordingly, the country of origin of the ratchet handle will be Vietnam. As we have determined that all articles in the set are o