OT:RR:NC:N1:104
M. Jason Cunningham
Sonnenberg & Cunningham PA
780 Fifth Ave South, Suite 200
Naples, FL 34102
RE: The country of origin of a manual grease gun
Dear Mr. Cunningham:
In your letter dated April 8, 2025, you requested a country of origin ruling on behalf of your client, Great Star
Industrial USA, LLC.
The item under consideration is a manual grease gun, used to apply lubricant (grease) to grease fittings on
machinery. It consists primarily of a strong steel canister (the barrel) that can hold bulk or standard sized
cartridges of grease, a head assembly at the top of the canister to direct the flow of grease through a tube and
into the grease fitting, and a large lever that applies force to push the grease from the canister through the
head assembly and into the grease fittings, usually through a hose or tube extension.
In your submission, you describe a scenario in which the grease guns will be produced from components
sourced from both Vietnam and China. The grease gun’s main parts are made from raw metal in Vietnam,
then finished and assembled in China together with small components of Chinese origin.
In Vietnam, raw steel is cut and rolled to form the canister blank. Also in Vietnam, aluminum is die-cast into
the final form of the gun’s head assembly, and raw steel is stamped into the hand lever blank. These
components are then sent to China where the head assembly is polished and powder coated. The canister’s
ends are threaded, and the canister is painted. The lever is bent, surface treated, and assembled with a plastic
grip. The three parts are assembled along with China-origin pins, seals, and knobs. The product is then
packaged with a China-origin hose and tube for export to the U.S.
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).
Based on the information provided, the character of the grease gun is imparted by the canister, head
assembly. and lever, all of which are produced in Vietnam. ?These key components maintain their name,
character, and use after being finished and assembled in China together with relatively minor China-origin
components. ?Therefore, the Vietnam-origin components are not substantially transformed in China.
Accordingly, the country of origin of the complete grease gun will be 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 Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division