The country of origin of an infrared transmitter and receiver

N353913
October 6, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of an infrared transmitter and receiver Dear Ms. Murrin: In your letter dated September 18, 2025, you requested a country of origin ruling on behalf of Lotus Laboratories, Inc. There are three items at issue with this request, which you state are all components of the Lotus Ring system. However, this request is meant to cover the country of origin of each component individually as they will not be packaged for retail sale until after importation. The first item is identified as the Lotus Ring, which is an Infrared (IR) transmitter meant to be worn on the user’s finger. The ring incorporates an IR module and switch that is designed to send a signal to a light switch in a user’s home. The IR signal either turns the light on or off, via the switch cover, which is described in the next paragraph. In your request, you state that the manufacturing process for the ring occurs in China. This begins with the creation of the flexible printed circuit (FPC), through surface mount technology (SMT), which incorporates the IR signal generation. This FPC is then glued to the inner part of the plastic housing before the battery is attached. The outer ring housing is then added to complete the ring. The second item is identified as the Switch Cover, which is designed to be installed over an existing light switch in the home. This device is comprised of a receiver printed circuit board assembly (PCBA) and an electric servo motor. When the PCBA receives the IR signal from the ring, it initiates the servo motor, which turns the switch on or off. The manufacturing process for the cover begins with the creation of the PCBA through SMT in Taiwan. We note that the PCBA receives and interprets the IR signal from the ring as well as providing certain safety features. The PCBA is then sent to China where it is installed within the plastic housing along with magnets, which allows the switch to be mounted to a standard wall switch. The servo motor, which originates in China, is installed with the battery. The housing is then completed to finish the assembly process.

The final item is the Ring Charger, which is an induction charger consisting of a PCBA and magnetic connection points within a molded housing. In use, the ring is placed on the top of the housing, coming in contact with the magnetic connections, thus charging the ring. The manufacturing process for the charger begins with the PCBA being created, through SMT, in Taiwan. The PCBA functions to convert the input voltage and control the electrical charging of the ring. The PCBA is then sent to China where it is placed within the plastic housing. 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). Regarding the origin of the subject articles, it is the opinion of this office that, in each case, the PCBA imparts the critical electrical functionality of each device. Furthermore, the assembly processes performed in China are simple in nature and would not effect a substantial transformation of the PCBA. Based upon the facts presented for the Lotus Ring, the country of origin will be China. The country of origin for the Switch Cover and Ring Charger will 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 Luke LePage at [email protected].
Sincerely,
(for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division