The country of origin of a satellite receiver

N350500
July 15, 2025
OT:RR:NC:N2:208
CATEGORY: Origin Helen Xiao Ernst & Young LLP 155 N Wacker Dr #2000 Chicago, IL 60606 RE: The country of origin of a satellite receiver Dear Ms. Xiao: In your letter dated June 23, 2025, you requested a country of origin ruling on behalf of your client, Shanghai DD&TT Electronic Enterprise Company Limited. The merchandise under consideration is referred to as the “Hopper 3 (Hopper),” which is a satellite receiver with a DVR tuner. The Hopper connects to a smaller receiver through Multimedia over Coax Alliance (MoCA). Moreover, this receiver consists of two main boards (a motherboard with core components and a Wi-Fi Board), two auxiliary boards (the power board and the button board), and other component parts. In Malaysia, the manufacturing of the motherboard printed circuit board assembly (PCBA), which controls all the critical operations, and the Wi-Fi Board, which provides access to the Internet to view Netflix and other streaming services occurs. This process consists of surface mount technology (SMT) and Through-Hole Technology (THT) processes. During these processes, numerous electronic components are permanently mounted onto raw printed circuit boards (PCBs) via soldering techniques, which results in fully functioning Malaysian PCBAs that can receive and process satellite signals. In China, the manufacturing of the power board, the button board, and the box build assembly process occurs. This assembly process involves the assembly of all the PCBAs with the rest of the components, including screwing on the chassis and the rubber feet. Lastly, the completed Hopper is visually inspected for defects. 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).

Based on the facts presented, it is our opinion that the motherboard PCBA and the Wi-Fi PCBA that are manufactured in Malaysia provide the primary functionality for the Hopper. The complex SMT manufacturing production of the motherboard PCBA and the Wi-Fi PCBA consists of placing and soldering numerous individual components onto a bare PCB, thereby, creating functional PCBAs that result in a substantial transformation. Further, the assembly process performed in China does not substantially transform the motherboards PCBA and the Wi-Fi board into a new and different article of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the Hopper is considered a product of Malaysia 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 Lisa Cariello at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division