The country of origin of the Steam Deck OLED gaming device

N347135
April 24, 2025
OT:RR:NC:N4:424
CATEGORY: Origin Michael Gamble Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of the Steam Deck OLED gaming device Dear Mr. Gamble: In your letter dated March 26, 2025, you requested a country of origin ruling on behalf of your client, the Valve Corporation. The article under consideration is identified as the Steam Deck OLED which is a handheld gaming device featuring a 7.4-inch HDR OLED (organic light emitting diode) touchscreen with a resolution of 1280 x 800 pixels. It has a refresh rate of up to 90hz. The Steam Deck is powered by a custom AMD Accelerated Processing Unit (APU) which combines a central processing unit with a graphics processor and includes 16 GB of LPDDR5 RAM. The Steam Deck supports WI-FI 6E and dedicated Bluetooth 5.3. and includes a USB-C port for power delivery and external display support. Additionally, it includes a 3.5mm stereo jack and onboard stereo speakers. The battery is designed for extended playtime and the included charger charges the device with a 45W power supply. The Steam Deck runs on the SteamOS operating system developed in the United States. After logging in on the Steam Deck, the user/player will have access to their entire catalog of games in their Steam library ready to play on the handheld device There are currently two models, the only differences between them being the storage options of a 512 GB NVMe (Non-volatile Memory express) SSD (Solid-State Drive) or a 1 TB NVMe SSD, and the 1 TB option is manufactured with anti-glare etched glass. The manufacturing process for both models is the same. The key components of the device include a main printed circuit board assembly (PCBA) which is manufactured in Thailand then shipped to China. This board integrates the processor, memory, solid-state drive, power management, and essential controllers for the device’s operation, and is mounted via surface mount technology (SMT) which is a manufacturing process for producing electronic circuits in which the components are mounted directly onto the surface of printed circuit boards. The main PCBA is the central processing hub and is critical to the Steam Deck’s functionality. It is responsible for running the operating system, processing game applications, managing power distribution, and interfacing with peripherals.

According to the information contained in your submission, there are three supporting PCBAs (input control boards, thumb stick boards, and audio board) which are manufactured in China using SMT. In China, the main PCBA and the supporting PCBAs are installed into the device’s housing, and firmware/software (developed in the United States) is loaded. The Steam Deck undergoes final testing and quality control before shipment. 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Regarding the country of origin of the subject Steam Deck gaming devices, in our view, the assembly of the main PCBA in Thailand by soldering the individual components onto the bare board results in a substantial transformation of the components to produce the main PCBA of Thai origin. Furthermore, it is the opinion of this office that the main PCBA is responsible for the core functionality of the gaming devices. It handles data processing, memory management, power distribution, and interfacing with peripherals. Without the main PCBA, the device would be unable to perform its intended functions as a gaming console. In our view, the assembly processes performed in China, which consists of inserting, attaching, screwing, etc., are not complex and are considered basic assembly. As a result, we find that the main PCBA of Thai origin is not substantially transformed in China into a different article of commerce with a new name, character and use. Thus, the Steam Deck gaming devices are considered products of Thailand for origin purposes at the time of importation into the United States. 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 Roseanne Murphy at [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division