CLA-2-82:OT:RR:NC:N4:415
Fay Jin
GreatStar Industrial USA, LLC
9836 Northcross Center Court, Suite A
Huntersville, NC 28078
RE: The classification and country of origin of an outdoor tool set from Vietnam.
Dear Ms. Jin:
In your letter dated July 25, 2025, you requested a classification and country of origin ruling.
The product under consideration is a five-piece outdoor tool kit. It includes the following items: a multi-tool,
an axe, a fixed blade knife, a hand trowel, and a fire starter kit. The multitool, axe, and hand trowel will each
come with a carrying pouch, the knife will have a sheath, and the fire starter kit will come in a metal box.
We note that the multi-tool and ax both feature a folding knife blade of stainless steel in their handles.
We hold the opinion that it is the knives of heading 8211 that would impart the essential character to this set,
General Rule of Interpretation 3(b) noted. The multi-tool, axe, and fixed blade knife will be sourced from
Vietnam and the hand trowel and fire starter kit will come from China.
The applicable subheading for this outdoor tool set will be 8211.10.0000, Harmonized Tariff Schedule of the
United States (HTSUS), which provides for “[k]nives with cutting blades, serrated or not (including pruning
knives), other than knives of heading 8208, and blades and other base metal parts thereof: [s]ets of assorted
articles.”
This set will be dutiable at the rate of duty applicable to that article in the set subject to the highest rate of
duty. The multi-tool provides the highest rate when considering all additional duties and compared to the
other equivalent ad valorem rates. The multi-tool is classified in subheading 8211.93.0031, HTSUS, which
has a general duty rate of 3 cents each plus 5.4 percent.
The complete tariff classification for this five-piece outdoor tool kit will be 8211.10.0000 / 8211.93.0031.
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.
As this product would be considered a set, we hold the opinion that the country of origin would be provided
by the source country for the knives, which is Vietnam. Therefore, the country of origin for this five-piece
outdoor tool kit would be Vietnam.
On March 12, 2025, Presidential proclamation 10896 imposed additional tariffs on certain derivative iron or
steel products. Additional duties for derivative iron or steel products of 50 percent are reflected in Chapter
99, headings 9903.81.89, 9903.81.90, and 9903.81.91. Products provided by heading 9903.81.91, as well as
products of Chapter 73 provided by 9903.81.89 and 9903.81.90, will be subject to a duty of 50 percent upon
the value of the steel content. At the time of entry, you must report the Chapter 99 heading applicable to
your product classification, i.e., 9903.81.91, in addition to subheadings 8211.10.0000 / 8211.93.0031,
HTSUS. Derivative iron or steel products processed in another country from steel articles melted and poured
in the United States, provided for in heading 9903.81.92, are not subject to the additional ad valorem duties.
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 of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. For products covered by heading 9903.81.91,
this additional duty applies to the non-steel content of the merchandise. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e., 9903.02.69, in addition to subheadings
8211.10.0000 / 8201.90.6000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status
of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may
refer to the relevant parts of the USTR and CBP websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.
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/current.
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, please contact
National Import Specialist Kristopher Burton at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division