OT:RR:NC:N4:415
Artem Kalajyan
Olympia Tools International, Inc.
929 North Grand Avenue
Covina, CA 91724
RE: The country of origin of utility knives from China.
Dear Mr. Kalajyan:
In your letter dated August 14, 2025, you requested a country of origin ruling.
The two products under consideration are both described as utility knives. The first type is a snap-off blade
style and the second is a standard utility knife with a blade that can be retracted into the handle.
For the snap-off blade utility knife, the components and processing consist of:
Steel blade is made in Taiwan by stamping and grinding.
Plastic blade slide button is made in China by injection molding.
Steel blade sleeve is made in China by stamping.
Plastic handle material is made in China by injection molding.
Assembly of the above components is completed in China.
Packaging is performed in China.
For the standard utility knife, the components and processing consist of:
Steel blade is made in Taiwan by stamping and grinding.
Steel blade holder is made in China by stamping.
Aluminum alloy handle is made in China by pressure casting.
Steel screw is made in China by stamping.
Assembly of the above components is completed in China.
Packaging is performed in China.
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.
In making a country of origin determination for these two utility knives, we look at Headquarters ruling letter
H311480, dated September 29, 2021. Similarly, we find that the Taiwanese blades are substantially
transformed into working knifes when assembly in China with the Chinese components. As such, we hold
the opinion that the country of origin for these two utility knives will be China.
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)
Denise Faingar
Acting Director
National Commodity Specialist Division