CLA-2-82:OT:RR:NC:N1118
Johnathan Cho
Johnathan Cho DBA A&A Customs Service
12140 Artesia Blvd., Ste 208
Artesia, CA 90701
RE: The tariff classification and country of origin of sockets, a drive bit socket and an impact socket adapter
Dear Mr. Cho:
In your letter dated July 11, 2025, you requested a tariff classification and country of origin determination
ruling on behalf of your client, World Honor Vietnam Co., Ltd., for sockets, a drive bit socket and an impact
socket adaptor. Each tool is made primarily of steel. You provided photographs and descriptions of the
manufacturing processes for each tool. The features and characteristics of the tools are as follows:
Item number DSC001-126 is identified as a drive socket. It is a one-piece tool that is cylindrical in
shape and hollow in the center. It features a square driver hole that fits into a ratchet or socket handle.
The other end is hexagonal and is used to tighten and loosen nuts and bolts.
Item number DBS001-20 is identified as a drive bit socket. It is a two-piece tool that is comprised of
a bit holder socket with a press-fit bit. The bit holder socket allows the tool to be attached to a square
driver of a wrench, ratchet handle, or power tool. The bit end is used to tighten or loosen screws.
Item number DIS001-20A is identified as an impact socket. It is a one-piece tool that is similar to a
drive socket, except it is designed to be used with pneumatic or electrical tools and has stronger
impact resistance and durability.
Item number DIS001-20B is identified as an impact socket adapter. It is a tool attachment that allows
you to use sockets or bits with tools like impact drivers or drills. It features a ball-lock mechanism
that prevents the socket or bit from falling off when in use.
Item number DEB001-32A is identified as a spark plug socket. It is a specialized type of deep socket
designed to remove and install spark plugs in an engine ignition system. The tool incorporates a
magnetic insert that securely holds the spark plug
Classification
The applicable subheading for the drive socket (item number DSC001-126), impact socket (item number
DIS001-20A) and the spark plug socket (item number DEB001-32A) will be 8204.12.0000, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for hand-operated spanners and wrenches
(including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles,
drives or extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof:
adjustable, and parts thereof. The general rate of duty will be 9 percent ad valorem.
The applicable subheading for the drive bit socket (item number DBS001-20) will be 8207.90.6000, HTSUS,
which provides for interchangeable tools for hand tools, whether or not power operated, or for machine-tools
(for example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling,
turning or screwdriving), including dies for drawing or extruding metal, and rock drilling or earth boring
tools; base metal parts thereof: other interchangeable tools, and parts thereof: other: other: not suitable for
cutting metal, and parts thereof: for handtools, and parts thereof. The general rate of duty will be 4.3 percent
ad valorem.
The applicable subheading for the impact socket adapter (item number DIS001-20B) will be 8466.10.0175,
HTSUS, which provides for Parts and accessories suitable for use solely or principally with the machines of
headings 8456 to 8465…; tool holders for any type of tool for working in the hand: Tool holders and
self-opening dieheads: Other. The general rate of duty will be 3.9 percent ad valorem.
Country of Origin
You submitted a narrative of the manufacturing process, along with production process flow charts and bills
of materials for each tool. For all of the tools, raw steel is sourced from China and sent to Vietnam and
manufactured into the finished tools. The manufacturing process includes cold forging the steel into the
overall shape of each tool and then further machining, such as chamfering, punching, grinding, polishing, etc.
In the case of the impact socket adaptor, a ball-lock mechanism is installed into the tool. In the case of the
drive bit socket, Chinese-origin steel is cut in Vietnam into the final form of the bit and inserted into the
socket. The spark plug socket is assembled with a Chinese-origin magnetic insert in Vietnam
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 sockets, drive bit socket and impact socket adaptor, it is our view that
raw steel is substantially transformed in Vietnam into finished tools. As demonstrated in your production
flow charts, all manufacturing, assembly and finishing operations occur in Vietnam. In the case of the impact
socket adapter and spark plug socket, the addition of the Chinese-origin steel ball, steel spring and magnetic
insert does not effect a substantial transformation on the steel tools. It is therefore the opinion of this office
that the country of origin of the drive socket, drive bit socket, impact socket, impact socket adaptor and spark
plug socket is Vietnam.
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 subheadings
8204.12.0000, 8207.90.6000, and 8466.10.0175, 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division