OT:RR:NC:N1:118
Eric Lee
Zhangjiagang Tianhua Hardware Co., Ltd.
26 Xinle Road, Daxin Town, Zhangjiagang City
Jiangsu Province
Zhangjiagang 215636
China
RE: The country of origin of pliers
Dear Mr. Lee:
In your letter dated January 2, 2026, you requested a country of origin ruling on five pairs of pliers, which are
identified as follows: bent nose pliers, end cutting pliers, flat nose pliers, needle nose pliers, and hose grip
pliers. Pictures of the tools in different stages of manufacture were included with your submission, along
with a narrative of the manufacturing process.
All five pliers have tapered jaws that are used for gripping, twisting, bending, cutting stripping and crimping
wires and other small objects. They are made of two pieces of steel, with each piece providing half of the
handles and half of the pair of jaws. When joined together, the joint provides a fulcrum that transfers and
increases the force applied to the handles by the user to the jaws.
The manufacturing process for the five pairs of pliers is substantially the same. It starts with drop-forging
raw steel rods in Thailand into the shape and form of the two halves of the pliers (i.e., the pieces
incorporating the handles and jaws). They are further die-cut and deburred to remove sharp edges and to
form the contours and profiles of each tool. The articles are then sent to China, where they are drilled with
holes and are joined together using rivet pins. The jaws are machined with teeth and/or cutting edges. The
pliers are sandblasted, heat treated, polished, and soft plastic or rubber grips are applied to the handles.
Finally, the pliers are adjusted for alignment, oiled and packaged for retail sale.
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).
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 pairs of pliers, it is our view that raw steel is substantially
transformed in Thailand, where it is forged, die-cut and deburred into the form of the two halves of the pliers
(i.e., the pieces incorporating the handles and jaws). These articles provide the principal characteristics and
main functionality of the finished tools, are dedicated for use as such, and cannot be used for any other
purpose. The character of these articles remains unchanged after the manufacturing processes and assembly
operations that occur in China. Therefore, it is the opinion of our office that the country of origin of the pair
of bent nose pliers, end cutting pliers, flat nose pliers, needle nose pliers, and hose grip pliers is Thailand.
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