OT:RR:NC:N1:118
Ling Tang
Zhejiang Feiling Tools Co., Ltd.
No.18 Huangliyang Industrial Estate, Qiantan Town
Jiande 311600
China
RE: The country of origin of a bit socket
Dear Ms. Tang:
In your letter dated January 6, 2026, you requested a country of origin determination for the purposes of
Section 301 and IEEPA duties, and for marking purposes under Section 304 of the Tariff Act of 1930, as
amended (19 U.S.C. 1304).
The item under consideration is identified as a bit socket. It is a tool comprised of a bit holder socket with a
press-fit bit. One end of the bit socket has a permanently attached bit (e.g., Philips head, Torx, Hex, etc.) that
is used to turn a screw head. The other end has a drive that allows the bit socket to be attached to a
screwdriver handle, ratchet handle, or power (electric or pneumatic) drill.
The manufacturing process for the bit socket takes place in two countries, Thailand and China. The bit is
wholly manufactured in Thailand from raw steel, where it cut to shape and size, and the tip of the bit is
machined to the required profile (e.g., Philips head, Torx, Hex, etc.). The socket holder is cold forged from
steel in China, then further machined to add precision. The Thai bit is sent to China and permanently affixed
to the socket holder using a hydraulic press.
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 bit socket, our office notes that the tool is comprised of two main components, i.e., a bit holder
socket and a bit. The bit holder socket allows for attachment to a handle or power tool for more torque. In this
particular case, we view that as an extension of the function and force of the bit. The permanent attachment
of the bit allows a user to apply more force than a replaceable bit. The bit is more durable because of this as
well. It is therefore our opinion that the bit, manufactured in Thailand, provides the essential characteristic of
the finished bit socket. Accordingly, the county of origin of the bit socket 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