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 screwdriver, pry bar, shears, and spinner handle
Dear Mr. Cho:
In your letter dated November 21, 2025, you requested a classification and country of origin ruling on behalf
of your client, World Honor Vietnam Co., Ltd., for four tools. The tools are primarily made of steel and are
identified as a screwdriver, pry bar, shears, and spinner handle. You provided samples of the tools, along
with photographs and descriptions of the manufacturing processes for each tool. The samples will be
returned as requested. The features and characteristics of the tools are listed below.
The screwdriver, item SDR001-19, incorporates a plastic handle attached to a steel shaft with a Torx head. It
is used to tighten and loosen Torx head fasteners.
The pry bar, item PRB001-2, incorporates a plastic handle attached to a steel flattened end that can be
inserted under an object to provide leverage and force. It is used to lift, separate or dismantle objects or
materials.
The shears, item SHR001-1, are multifunctional scissors with plastic finger ring handles and steel shear
cutting blades. They are used to cut different lightweight materials, such as paper, fabric and rope.
The spinner handle, item SPH001-1, is a screwdriver-shaped tool with a plastic handle and integrated steel
shaft. The end of the steel shaft features a 1/4" square drive that attaches to various sockets. The product’s
design and construction enables the user to spin the socket like a screwdriver, allowing for rapid installation
of nuts or bolts.
Classification
The applicable subheading for the screwdriver, item SDR001-19 will be 8205.40.0000, Harmonized Tariff
Schedule of the United States (HTSUS), which provides for handtools (including glass cutters) not elsewhere
specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than
accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or
pedal-operated grinding wheels with frameworks; base metal parts thereof: screwdrivers, and parts thereof.
The general rate of duty will be 6.2 percent ad valorem.
The applicable subheading for the pry bar, item PRB001-2, will be 8205.59.3010, HTSUS, which provides
for handtools (including glass cutters) not elsewhere specified or included; blow torches and similar
self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools or
water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with
frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: other:
crowbars, track tools and wedges, and parts thereof: crowbars. The general rate of duty will be free.
The applicable subheading for the shears, item SHR001-1, will be 8213.00.9000, HTSUS, which provides for
scissors, tailors’ shears and similar shears, and blades and other base metal parts thereof: valued over
$1.75/dozen: Other (including parts). The general rate of duty will be 3 cents each plus 3 percent ad valorem.
The applicable subheading for the spinner handle, item SPH001-1, 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 processes, along with production process flow charts and
bills of materials for the four tools. For each tool, steel is sourced from China and sent to Vietnam where it is
wholly manufactured into the finished product. The manufacturing process starts with cutting the steel into
the overall shape of each tool. Further processing in Vietnam includes heat-treatment, electroplating,
polishing, 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 four 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 screwdriver, pry bar, shears, and spinner handle 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
8205.40.0000, 8205.59.3010, 8213.00.9000 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division