OT:RR:NC:N4:415
M. Jason Cunningham
Sonnenberg & Cunningham, PA
780 Fifth Avenue South, Suite 200
Naples, FL 34102
RE: The country of origin of two types of utility blades from Vietnam.
Dear Mr. Cunningham:
In your letter dated April 9, 2025, you requested a country of origin ruling on behalf of your client, Great Star
Industrial USA, LLC.
Images were provided in lieu of samples.
The products under consideration are utility knife blades made from steel. They will both be imported in a
multipack of blades and without a knife handle.
The first is a hook blade. A hook blade is a blade with a hook at either end used to cut through thick
materials without damaging underlying material. Hook blades are commonly used in construction, roofing,
flooring, and other work that requires cutting difficult materials. Hook blades are especially useful for
cutting through materials that are difficult to slice with a standard blade, such as carpet, vinyl, roofing felt,
rubber, and various types of fabrics.
The second is a standard utility blade. This utility blade is the most common blade type for use with utility
knives. It is commonly and commercially called a “utility blade,” a “trapezoidal” blade, or an “all-round”
blade.
Hook Blade Production:
In China, a raw steel strips are punched and pressed into long strips of notched, connected blade blanks.
They have the characteristic hooks at both ends, two notches on the opposite edge for insertion into a utility
handle, and a center hole punch. The strip is heat treated in Vietnam, then each hook blade blank is divided
from the strip and shipped to China. The blanks sent to China have the final shape, size, and form of the
finished hook blade when exported from Vietnam. In China, the blanks are sharpened, then packaged for
export to the United States.
Utility Blade Production:
The trapezoidal utility blade is punched into strips of blade blanks from raw steel in Vietnam. The strips of
blades are heated treated in Vietnam, then sharpened in Vietnam. Finally, the sharpened blades are divided
from the strips into individual blades in Vietnam before shipment to China where each blade is surface
treated, then packaged into multipacks for export to the United States.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (?HQ?) 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 order to determine whether a substantial transformation occurs when components are assembled into
completed products, all factors such as the components used to create the product and manufacturing
processes that these components undergo are considered in order to determine whether a product with a new
name, character, and use has been produced. ?No one factor is decisive, and assembly/manufacturing
operations that are minimal will generally not result in a substantial transformation.
This office reviewed the submitted production process of these two types of knife blades. We hold the
opinion that the blade blanks hold the essential identity of the finished blades and the further processing in
China would not substantially transform them. This would be consistent with the cited Headquarters Ruling
letter 559366, dated August 29, 1995. As such, we hold the opinion that the country of origin for the hook
and utility blades would 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 CBP Regulations (19 CFR 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, contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division