The country of origin of a mechanical keyboard module

N353885
October 15, 2025
OT:RR:NC:N2:208
CATEGORY: Origin Yan Xiao Solid Year Co., Ltd. 18F-11., No.97, Sec. 1, Xintai 5th Rd., Xizhi Dist. New Taipei City 221416 Taiwan RE: The country of origin of a mechanical keyboard module Dear Mr. Xiao: In your letter dated September 18, 2025, you requested a country of origin ruling on the modular version of a mechanical keyboard on behalf of your client, Wooting Store B.V. The merchandise under consideration is identified as “W05T011 Mechanical Keyboard (modular version),” which includes disassembled keyboard components intended to be used in building and designing a personalized keyboard with lighting effects. The modular mechanical keyboard is comprised of components consisting of: Wooting 60HE module, EPDM dampening foam, EVA foam lid as temporary case, USB-C cable, 10 silicone stand-off protection sticker, Poron Sandwich Pad, and 7 PH1 M2 White Screws. After importation, the user assembles the keyboard components into a case of their choosing, where one can add switches and keycaps to complete building the customized mechanical keyboard and making it functional. Based on the information provided, the subject mechanical keyboard module is made up of individual components, such as microcontrollers, hall-effect sensors, switches, printed circuit board (PCB), plastic housing, stabilizers, USB cable, and other subassemblies, which are fabricated in both China and Taiwan. In Taiwan, the various components are placed onto the PCB using solder paste application, surface mount technology (SMT), and through-hole assembly. Firmware is then added, and the mechanical keyboard module is tested for functionality, and the finished product is packaged for export to the United States. 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 the opinion of this office that the origin of the modular keyboard is the country in which the PCBA is produced using solder paste application, SMT, and through-hole assembly. The manufacturing process performed in Taiwan substantially transforms the Chinese components into a mechanical keyboard module. As a result, we find that the country of origin of the W05T011 Mechanical Keyboard (modular version), to be Taiwan. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division