National Hand Tool Corp. v. United States
United States Court of International Trade
16 Ct. Int’l Trade 308 (1992)
- Written by Gonzalo Rodriguez, JD
Facts
National Hand Tool Corporation (National) (plaintiff) imported from Taiwan nine kinds of parts—handle bars, “G” heads, and flex handles, among others— used to put together mechanics’ hand tools in the United States. These parts underwent additional manufacturing in the United States, including the reshaping of handle bars and knurling of the handles to create a gripping surface. Some of the parts were heat treated, and some were electroplated with nickel and chrome to resist rust, in the United States. After undergoing these processes, the parts were then assembled into the final product. The United States Customs Service (customs) (defendant) determined that the parts were not substantially transformed in the United States and required that the parts be marked to indicate Taiwan as the country of origin. National challenged customs’ determination, arguing, among other things, that the post-importation processes added significant value to the product.
Rule of Law
Issue
Holding and Reasoning (DiCarlo, C.J.)
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