The country of origin of a USB Hub

N341280 July 26, 2024 OT:RR:NC:N2:220 CATEGORY: Origin Jessica Chen Cable Technology Corp. 5F, No.58, Chungshan North Rd. Sec.3 Taipei, 104 Taiwan RE:      The country of origin of a USB Hub Dear Ms. Chen: In your letter dated July 15, 2024, you requested a country of origin ruling. The merchandise under consideration is identified as the USB-C 11-in-1 Hub (Hub), Item No. C112H-R, which is described as an aluminum enclosure containing a printed circuit board assembly (PCBA) that has multiple connection ports and sockets, such as USB, HDMI, SD card slots, and an RJ45 port.  In use, the Hub is connected to an automatic data processing machine for the purpose of connecting peripherals, such as a mouse, keyboard, and/or monitor, as well as memory cards and network connectivity. You state that the Hub is assembled in Taiwan by placing the PCBA into the aluminum housing, installing a plastic end cap, and conducting quality and functional testing.  The PCBA is manufactured in China by soldering electronic components onto a bare printed circuit board. The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. 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 U.S. the English name of the country of origin of the article. The “country of origin” is defined in 19 CFR 134.1(b) 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 this part.”  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, 69 C.C.P.A. 151 (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). Regarding the country of origin of the Hub, in our view, the assembly of the PCBA in China by soldering individual electronic components onto a bare board results in a substantial transformation of the components to produce a PCBA of Chinese origin.  Furthermore, it is the opinion of this office that the PCBA, which functions to interconnect the peripherals to the attached computing device, establishes the character of the Hub.  Based on the information provided, the assembly of the Hub by inserting the PCBA into an aluminum housing and functional testing in Taiwan is not complex and does not substantially transform the PCBA into a different article of commerce with a new name, character, and/or use.  Thus, the USB-C 11-in-1 Hub, Item No. C112H-R, is considered a product of China for origin and marking purposes at the time of importation into the United States. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Karl Moosbrugger at [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division