CLA-2-82:OT:RR:NC:N1:118
Eric Lee
Zhangjiagang Tianhua Hardware Co., Ltd.
XinLe Rd., DaXing Town
Zhangjiagang 215636
China
RE: The tariff classification and country of origin of long nose pliers, linesman pliers, and diagonal pliers
Dear Mr. Lee:
In your letter dated May 7, 2025, you requested a tariff classification and country of origin determination
ruling.
In your letter dated May 7, 2025, you requested a tariff classification and country of origin determination
ruling for three different types of pliers. The pliers are identified as long nose pliers, linesman pliers, and
diagonal pliers. You provided photographs and descriptions of each stage of the manufacturing process for
each of the pliers. The features and characteristics of the pliers are as follows:
Long nose pliers (also known as needle-nose pliers) are gripping, pinching, and holding pliers. They
incorporate long thin jaws with a small cutting edge near the pliers’ joint. They are made of two pieces of
steel, with each piece providing half of the handle and half of the working end. When joined together, the
joint provides a fulcrum that transfers and increases the force applied to the handles by the user to the
working end.
Lineman pliers are a type of pliers used by linemen, electrical contractors, and other tradesmen primarily for
gripping, twisting, bending, and cutting wire, cable, and small metalwork components. They are made of two
pieces of steel, with each piece providing half of the handle and half of the working end. They have a
beveled cutting edge near the joint of the working end’s jaw and teeth for gripping at the end of the nose.
Diagonal pliers are used for cutting wire. They are made of two pieces of steel, with each piece providing
half of the handle and half of the working end. The plane defined by the cutting edges of the jaws intersects
the joint rivet at an angle or “on a diagonal.” The jaw edges are ground to a symmetrical “V” shape, and they
cut by indenting and wedging the wire apart.
The applicable subheading for the long nose pliers, linesman pliers, and diagonal pliers, will be
8203.20.6030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for files, rasps,
pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating
punches and similar handtools, and base metal parts thereof: Pliers (including cutting pliers), pincers,
tweezers and similar tools, and parts thereof: Other: Other (except parts). Pliers. The general rate of duty will
be 12¢/doz. + 5.5% ad valorem.
You describe the manufacturing processes for the three pliers as follows:
The handles and jaws of the Long Nose Pliers are drop-forged from raw steel rods in Thailand, forming the
rough shape of each. Further in Thailand, each handle is die-cut, deburred, and sandblasted. The two halves
of the pliers (i.e., the pieces incorporating the handles and jaws) are then sent to China, where two holes are
drilled into each piece so that they can be joined together. Teeth are then cut into the jaws, and the pieces
undergo heat-treatment and polishing. Finally, the two halves are assembled with rivets, soft grips are
slipped over the handles, and the finished pliers are packaged for retail sale.
The manufacturing process for the Linesman Pliers involves drop-forging raw steel rods in Thailand to create
the basic shape of the handle and jaw. The handle and jaw blanks are then die-cut, deburred, and sandblasted
to remove any sharp edges. The two halves are then sent to China, where holes are drilled into each blank,
and teeth are cut into the jaws. They are joined together by rivets and the pliers are heat-treated and
polished. Finally, the handles are covered with soft grips and the finished pilers are packaged for retail sale.
The manufacturing process for the Diagonal Pliers involves the drop-forging raw steel rods in Thailand to
produce the two handle and jaw pieces of the pliers. These two pieces are also die-cut, deburred, and
sandblasted. The two halves are then sent to China, where holes are drilled into each blank, and teeth are cut
into the jaws. They are joined together by rivets and the pliers are heat-treated and polished. Finally, the
handles are covered with soft grips and the finished pilers 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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
Regarding the country of origin of the three pliers, it is our view that raw steel is substantially transformed in
Thailand into identifiable blanks of the finished tools. This includes drop-forging and die-cutting steel into
the handles and jaws of the pliers. These articles provide the principal characteristics of the finished tools,
are dedicated for use as such, and cannot be used for any other purpose. ?The character of these articles
remains unchanged after the manufacturing processes and assemblies that occur in China. Therefore, it is the
opinion of our office that the country of origin of the long nose pliers, linesman pliers, and diagonal pliers is
Thailand.
Effective April 5, 2025, Executive Orders implemented ?Reciprocal Tariffs. ?All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. ??At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
8203.20.6030, HTSUS, listed above.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS
and the accompanying duty rates are provided at https://hts.usitc.gov/.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division