OT:RR:NC:N1:118
Fay Jin
GreatStar Industrial USA, LLC
9836 Northcross Center Court, Suite A
Huntersville, NC 28078
RE: The country of origin of a tap, die and spiral screw extractor
Dear Ms. Jin:
In your letter dated July 21, 2025, you requested a country of origin determination for purposes of Section
301 and IEEPA duties. Pictures of the merchandise in different stages of manufacture were included with
your submission, along with a narrative of the manufacturing processes.
The three steel tools under consideration are a tap, die and spiral screw extractor. Taps are used to cut
internal threads within a hole in a workpiece, while dies are used to cut external threads on screws, bolts,
rods, or studs. Tap wrenches and die stocks hold the tap or die while in use. A spiral screw extractor is a
specialized tool designed to remove broken, stripped or stuck screws and bolts. Typically, a power drill is
used to hold and turn the extractor while in use.
The manufacturing process for the tap begins in Thailand, where steel rods are cut to the overall size and
shape of the tap. The outer threads are rolled onto the tap, and the shank and drive of the tool are ground.
The tap is then sent to China, where the chamfered end is formed and, in some instances, flutes or grooves
are ground into the threads.
The manufacturing process for the die begins in Thailand, where steel rods are cut and chamfered into the
outer shape and size of the die. The die is then put through a multi-station milling machine where the center
of the die is cut out and the internal threads are milled. After this process, the die is sent to China for
deburring, further chamfering, heat-treatment, sandblasting, and laser etching.
The manufacturing process for the spiral screw extractor begins in Thailand, where steel rods are cut into the
length of the tool. The shank and dive are ground and threads are rolled onto the extractor before it is sent to
China. In China, the extractor is heat-treated, sandblasted and a logo is laser etched onto it.
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 tap and die, it is our view that steel rod is substantially transformed in Thailand into
recognizable tool blanks in each of your manufacturing scenarios. Based on the submitted information and
pictures of the tools, it is our opinion that no article emerges from the finishing operations in China with a
new name, character, or use different from that prior to processing. Although not ready for direct use, the tool
blanks that arrive in China have a pre-determined use and are in a dedicated physical form of a die and tap.
Therefore, it is our determination that the country of origin of the tap and die is Thailand.
In regard to the spiral screw extractor, we find that steel is substantially transformed in Thailand into a fully
formed spiral screw extractor. It is not substantially changed by heat-treatment, sandblasting or having a
logo laser etched into it. Therefore, it is our determination that the country of origin of the spiral screw
extractor is Thailand.
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