CLA-2-82:OT:RR:NC:N1:118
Fay Jin
GreatStar Industrial USA, LLC
9836 Northcross Center Court, Suite A
Huntersville, NC 28078
RE: The tariff classification and country of origin of a hand tool set
Dear Ms. Jin:
In your letter dated April 15, 2026, you requested a tariff classification and country of origin determination
for purposes of Section 301 and other duties. A sample of the merchandise was submitted for review and
will be retained by our office.
The sample is identified as a WORKPRO 19-Piece Household Tool Set (item number WP209157). You state
that the set will be packaged in China with the following Chinese and Vietnamese items:
1PC 8-inch Linesman Pliers (Vietnam)
1PC 6-inch Long Nose Pliers (Vietnam)
1PC 7-inch Diagonal Pliers (Vietnam)
1PC 8-inch Wire Stripper (Vietnam)
1PC 10-inch Water Pump Pliers (Vietnam)
1PC 10-inch Adjustable Wrench (Vietnam)
1PC 12-ounce Hammer (Vietnam)
8PCS Screwdrivers (Vietnam)
1PC 8.5-inch Scissors (China)
1PC 16-foot Measuring Tape (China)
1PC 9-inch Level (China)
The items will be imported packaged for retail sale in a Chinese-origin tool case. The sample of the tool case
you submitted is made of molded plastic and has specially fitted compartments for each item in the set.
Classification
The applicable subheading for the WORKPRO 19-Piece Household Tool Set (item number WP209157), will
be 8206.00.0000, Harmonized Tariff Schedule of the United States (HTSUS) which provides for tools of two
or more of the headings of 8202 to 8205, put up in sets for retail sale. Heading 8206 requires that duty be
applied to that article in the set subject to the highest rate of duty. The article in this set subject to the highest
rate of duty is the water pump pliers, classifiable in subheading 8203.20.4000, which provides for slip joint
pliers. The general rate of duty will be 12% ad valorem. The complete classification of the set will be
8206.00.0000 / 8203.20.4000.
Country of Origin
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).
As your product is considered a hand tool set, we hold the opinion that the country of origin would be
provided by the source country of the hand tools, which is Vietnam. These tools do not lose their identity or
character when they are packaged in China with the other Chinese-origin items. Therefore, the country of
origin for the WORKPRO 19-Piece Household Tool Set (SKU No. WP209157) is Vietnam.
The duties cited above are current as of this ruling’s issuance. 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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)
James P. Forkan
Director
National Commodity Specialist Division