N355866

N355866 November 26, 2025 OT:RR:NC:N1:118 CATEGORY: Origin Lawrence Friedman Barnes, Richardson & Colburn LLP 303 East Wacker Drive, Suite 305 Chicago, IL 60601 RE: The country of origin of a hex key set and Torx folding keys Dear Mr. Friedman: In your letter dated November 7, 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 Hex Key Set and 8pc Micro Torx Folding Keys. The Hex Key Set includes various sizes of hex keys that are imported in a plastic holder. They are used to tighten and loosen hexagonal head fasteners. The 8pc Micro Folding Keys includes eight various sizes of Torx keys that will be imported in a folding plastic holder. They are used to tighten and loosen Torx head fasteners. The manufacturing process for the Hex Key Set begins in Vietnam, where Chinese-origin spring steel bars are cold forged into hexagonal shapes. After forging, each long hexagonal bar is fed into a machine and cut to the precise length for each hex key. Using a ball end machine, each key is bent at a 90-degree angle to form an L shape. Once formed, the hex keys are shipped to China where they are heat treated, cleaned, polished and plated. Finally, the hex keys are assembled into a plastic holder. The manufacturing process for the 8pc Micro Torx Folding Keys is similar to the Hex Key Set. It begins in Vietnam, where Chinese-origin spring steel bars are formed into a rod with a diameter and length of each Torx key. The rods are then put into a CNC machine, where the Torx ends are formed and the back end is bent into a curved shape. The keys are shipped to China, where they are heat treated, cleaned, polished, and coated for rust prevention. Finally, the curved end of each key is assembled into a folding plastic holder. 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). Regarding the Hex Key Set and the 8pc Micro Torx Folding Keys, it is our view that spring steel bars are substantially transformed in Vietnam into recognizable tool blanks of each individual tool. In the case of the hex keys, the hexagonal heads are formed, and they are bent to a 90-degree angle. Similarly, the blade end of each Torx folding key is formed in Vietnam and the back end is bent into a curved shape. Based on the submitted information and pictures of the finished items, it is our opinion that no article emerges from the finishing or assembly operations in China with a new name, character, or use different from that prior to processing. Therefore, it is our determination that the country of origin of the Hex Key Set and the 8pc Micro Torx Folding Keys 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) Deborah Marinucci 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). Regarding the Hex Key Set and the 8pc Micro Torx Folding Keys, it is our view that spring steel bars are substantially transformed in Vietnam into recognizable tool blanks of each individual tool. In the case of the hex keys, the hexagonal heads are formed, and they are bent to a 90-degree angle. Similarly, the blade end of each Torx folding key is formed in Vietnam and the back end is bent into a curved shape. Based on the submitted information and pictures of the finished items, it is our opinion that no article emerges from the finishing or assembly operations in China with a new name, character, or use different from that prior to processing. Therefore, it is our determination that the country of origin of the Hex Key Set and the 8pc Micro Torx Folding Keys 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