CLA-2-82:OT:RR:NC:N1:118
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 an extension bar, a socket adapter, an extended spark
plug socket, a flex head spark plug socket and a universal joint socket
Dear Mr. Cho:
In your letter dated July 31, 2025, you requested a tariff classification and country of origin determination
ruling on behalf of your client, World Honor Vietnam Co., Ltd. The items under consideration are primarily
made of steel and are identified as an extension bar, a socket adapter, an extended spark plug socket, a flex
head spark plug socket and a universal joint socket. You provided photographs and descriptions of the
manufacturing processes for each tool. The features and characteristics of the tools are listed below.
Item number DEB001-32F is an extension bar. It is a tool that connects a drive tool (e.g., ratchet) and a
socket. It is used to increase the reach of a socket and ratchet, allowing access to fasteners that are recessed
or located in hard-to-reach areas. It features a ball-lock mechanism that prevents the socket from falling off
when in use.
Item number DEB001-32D is a socket adapter. It is a tool that enables the use of various socket sizes with
tools that have different drive sizes. It features a ball-lock mechanism that prevents the socket from falling
off when in use.
Item number DEB001-32C is an extended spark plug socket. It is a socket designed for removing and
installing spark plugs in vehicles and small engines. Its extended design allows easier access to spark plugs,
especially in tight or deep engine compartments.
Item number DEB001-32B is a flex head spark plug socket. It is a specialized socket designed to make
removing and installing spark plugs easier, especially in hard-to-reach areas. Its elongated design and
flexible head allow for greater maneuverability.
Item number DEB001-32E is a universal joint socket. It is a specialized socket that incorporates a swiveling
joint, allowing it to articulate and reach fasteners at various angles.
Classification
The applicable subheading for the extended spark plug socket (item number DEB001-32C), flex head spark
plug socket (item number DEB001-32B) and the universal joint socket (item number DEB001-32B) will be
8204.20.0000, 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: socket wrenches, with or without
handles, drives and extensions, and parts thereof. The general rate of duty will be 9 percent ad valorem.
The applicable subheading for the extension bar (item number DEB001-32F) and the socket adapter (item
number DEB001-32D) 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 some cases, small Chinese-origin parts (e.g. a ball-lock mechanism, a magnet, a rubber ring) are
assembled with the tools 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 five tools under consideration, 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. The assembly with small Chinese
origin parts, such as a ball-lock mechanism, a magnet or rubber ring, 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
extension bar, socket adapter, extended spark plug socket, flex head spark plug socket and universal joint
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 of Vietnam will be
subject to an additional ad valorem rate of duty of 20 percent. 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
8204.20.0000, 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