OT:RR:NC:N1:118
Fay Jin
GreatStar Industrial USA, LLC
9836 Northcross Center Court, Suite A
Huntersville, NC 28078
RE: The country of origin of an automatic spring-loaded center hole punch
Dear Ms. Jin:
In your letter dated December 26, 2025, you requested a country of origin determination for the purposes of
Section 301 and IEEPA duties. Pictures of the item in different stages of manufacture were included with
your submission, along with a narrative of the manufacturing processes.
The merchandise is identified as an automatic spring-loaded center hole punch. It is a hand-operated tool
used to create an indentation on wood or metal surfaces prior to drilling, fastening, or marking. The tool
operates through an internal spring-loaded impact mechanism that delivers force when downward pressure is
applied, without the use of a hammer or external power source. It consists of a lightweight aluminum body
containing alloy steel internal components and a hardened steel punch pin. The spring tension is adjustable to
allow use on materials of varying hardness. The product is manually operated, non-electric, and intended for
general workshops, mechanical and automotive repair, and household applications. The item has an overall
length of approximately 5.1 inches and a net weight of approximately 3.98 ounces.
The manufacturing process for the automatic spring-loaded center hole punch begins in Vietnam, where raw
steel is cold headed to the required size and rough shape of the punch pin. The punch pin is then machined to
form a pointed tip. After this initial forming, the punch pin is shipped to China, where it undergoes further
heat treatment and electroplating. The shell body, shell head, shell cap, ejector pin, ejector spring, guide
bushing and cap spring used in the assembly are of Chinese origin. These components, together with the
punch pin, are assembled in China to produce the finished tool.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional 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).
In considering your manufacturing scenario, there is no dispute that the punch pin, which is manufactured in
Vietnam is dedicated for use in the finished automatic spring-loaded center hole punch. However, while this
is a consideration, it does not assure a finding of substantial transformation. As the court stated in National
Hand Tool, we must look at the totality of the evidence. We also must consider the product at issue, how it
functions, and the purpose of the components within it carrying out its function. The automatic spring-loaded
center hole punch operates by means of an internal spring-loaded impact mechanism. It is this mechanism
that enables the tool to deliver a downward force without the use of a hammer and provides the essential
functionality of the tool. The components of this mechanism are entirely of Chinese-origin. Furthermore, the
assembly of these components, along with the punch pin occurs in China. Therefore, the totality of the
evidence leads our office to conclude that the country of origin of the finished automatic spring-loaded center
hole punch is 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 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