Country of origin marking of Smart Glasses; Section 301

HQ H345669
July 23, 2025
OT:RR:CTF:VSP H345669 ACH
CATEGORY: Origin
Ms. Suzanne Kane
Akin Gump Strauss Hauer & Feld LLP
2001 K Street, N.W.
Washington, DC 20006-1037
Re: Country of origin marking of Smart Glasses; Section 301
Dear Ms. Kane:
This is in response to your correspondences, dated March 6, 2025 and March 20, 2025,
requesting a binding ruling on behalf of your client, [ ] concerning the country of origin of two
different models of Smart Glasses for marking, and Section 301 duty purposes. Either [ ] or [ ]
will act as the importer of record.
You have requested that certain information submitted in connection with this request be
treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R.
§ 177.2(b)(7), the request for confidentiality is approved. The information bracketed in your
request will not be released to the public and will be withheld from published versions of this
ruling.
FACTS:
1. [ ] Smart Glasses - Model #1
The Next Generation Smart Glasses addressed in the March 6, 2025 inquiry are artificial
intelligence (“AI”) glasses that offer users the opportunity to capture photos and videos, make
video calls or livestream, store photos and videos, listen to music, make phone calls, send texts
using voice commands, and ask questions and receive answers using AI. The Smart Glasses
have a front frame, right and left temple pieces, and two lenses. The lenses of the Smart Glasses
are available as prescription or non-prescription, depending on what the customer chooses. The
customer has the option to select polarized or non-polarized sunglass lenses, transition, blue
filter, or clear form lenses.
The Smart Glasses are equipped with a [ ] chipset that is mounted to the main logic board
(“MLB”) within the product. The Smart Glasses incorporate a high-power main processing unit
that handles heavy computing including photo and video processing, wireless communication,
2
and AI functionalities; a microcontroller unit (“MCU”) that handles lower computing
functionalities such as sensor processing, audio playback, and microphone capture; components
that provide memory storage; and components that provide capacitive touch functionality,
allowing users to interact with the Smart Glasses through touch gestures.
All of these functions are made possible by the chipset mounted on the MLB, which is
responsible for the flow of data, power, and communication between the major components. The
main components of the Chipset include the applications processor, which handles instructions,
manages memory, manages power, processes all multimedia, and ensures that all parts and
components are communicating with each other to fully integrate operations, and the WiFi/Bluetooth chip, which enables Wi-Fi and Bluetooth connectivity for the device.
It is stated that the MLB drives the functioning of the Smart Glasses through visual and
audio feedback from several other components, including:
? The Secondary Logic Board (“SLB”) (surface mounted in Vietnam), which is an
auxiliary PCBA that is responsible for enabling and amplifying the audio of the speaker
on the right temple flexible printed circuit board. The SLB also contains an action button
that allows the user to activate video or streaming. The SLB supports the communication
capabilities of the Smart Glasses by enabling the speaker to perform key functions by
engaging the action button.
? Flexible Printed Circuit Boards (“FPCAs”), which are responsible for connecting the
different components of the Smart Glasses to each other and directly or indirectly to the
MLB. The Superflex FPCA contains a microphone and connects to the MLB, camera,
SLB, and charging contacts. The Camera FPCA contains the camera module and
connects to the Superflex FPCA. The Right Temple FPCA contains two microphones, an
integrated circuit (“IC”), and right speaker pads and connects to the SLB and the right
temple speaker. The left temple FPCA contains two microphones and left speaker pads
and connects to the MLB and the left speaker. The Slider FPCA contains a two-position
switch and connects to the MLB.