CLA-2-82:OT:RR:NC:N1:118
Johnathan Cho
Johnathan Cho DBA A&A Customs Service
12140 Artesia Blvd.
Artesia, CA 90701
RE: The tariff classification and country of origin of a breaker bar, locking chain pliers and locking pliers
Dear Mr. Cho:
In your letter dated October 21, 2025, you requested a classification and country of origin ruling on behalf of
your client, World Honor Vietnam Co. Ltd., for three tools. The tools are primarily made of steel and are
identified as a breaker bar, locking chain pliers and locking pliers. You provided photographs and
descriptions of the manufacturing processes for each tool. The features and characteristics of the tools are
listed below.
The breaker bar, item BBR001-4, incorporates a cylindrical handle that is attached to a flexible joint and a
square drive head, which can be attached to a socket. The tool provides extra leverage to a socket when
removing overtightened nuts and bolts.
Locking chain pliers, item LCP001-1, are used for gripping and holding large irregularly shaped objects, or
delicate objects that standard locking pliers or wrenches cannot handle. The tool incorporates a chain that is
wrapped around the object or objects that need to be gripped. The chain is then threaded through a lock on
the head, allowing the user to crank the handle to apply tension. Once secure, the chain can be locked in
place by a locking mechanism that is incorporated into the handles.
Locking pliers, item LOP001-5, incorporate adjustable jaws that lock into a fixed position, allowing them to
firmly grip and hold objects without the need for continuous hand pressure. The jaws can be tightened by a
screw or knob and released by a lever, making them versatile for a wide range of tasks, from gripping and
turning nuts to holding parts in place while welding.
Classification
The applicable subheading for the locking pliers, item LOP001-5, will be 8203.20.6030, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for files, rasps, pliers (including cutting pliers),
pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools,
and base metal parts thereof: pliers (including cutting pliers), pincers, tweezers and similar tools, and parts
thereof: other: other (except parts): pliers. The general rate of duty will be 12¢/doz. + 5.5 percent ad valorem.
The applicable subheading for the locking chain pliers, item LCP001-1, will be 8203.20.6060, HTSUS,
which provides for files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe
cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof: pliers (including
cutting pliers), pincers, tweezers and similar tools, and parts thereof: other: other (except parts) other. The
rate of duty will be 12¢/doz. + 5.5 percent ad valorem.
The applicable subheading for the breaker bar, item BBR001-4, 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 three tools, steel is sourced from China and sent to Vietnam where it is
wholly manufactured into the finished tools. The manufacturing process starts with forging the steel into the
overall shape of each tool. Further processing in Vietnam includes heat-treatment, electroplating, machining,
laser marking, testing, assembly and packaging.
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 country of origin of the five tools under consideration, it is our view that raw steel is
substantially transformed in Vietnam into the finished tools. As demonstrated in your production flow charts,
all manufacturing, assembly and finishing operations occur in Vietnam. It is therefore the opinion of this
office that the country of origin of the breaker bar, locking chain pliers and locking pliers 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
8203.20.6030, 8203.20.6060 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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division