The country of origin of handheld electronic devices

N354327
October 22, 2025
OT:RR:NC:N2:208
CATEGORY: Origin Rosanna Iannello Datalogic USA Inc. 959 Terry Street Eugene, OR 97402 RE: The country of origin of handheld electronic devices Dear Ms. Iannello: In your letter dated September 29, 2025, you requested a country of origin ruling. The merchandise under consideration is referred to as the MEMOR™ 11 Family of mobile computers. These handheld electronic devices are used for data capture and mobile applications, consisting of a handheld mobile computer and a full-touch PDA (Personal Digital Assistant) with 4GB of RAM, a 5-inch capacitive multi-touch HD display, the Android 13 system with Google Mobile Services (upgradeable to Android 15), and a high-end 2D scan engine for scanning and reading barcodes. As per the information provided, all components, including the upper enclosure, display, Wi-Fi brackets, mainboard (PCBA), camera, lower enclosure, battery cover enclosure, etc., are manufactured in China. In Vietnam, final assembly takes place, including the attachment of Chinese components such as the front and rear housings (injection-molded), plastic brackets and internal covers, the mainboard, the camera module, the battery cover, and minor fasteners (screws, plugs). The manufacturing of the optical module (scan engine), firmware installation, and quality inspection also occur in Vietnam. 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 MEMOR™ 11 Family of mobile computers is the country in which the mainboard (PCBA) is produced. Accordingly, the Chinese mainboard imparts the prominent character of the device since it performs the primary and vital functions of

the MEMOR™ 11 Family of mobile computers. In this case, the mainboard (PCBA) is made in China, and the assembly process performed in Vietnam would not substantially transform the mainboard into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, we find that the country of origin of the subject handheld electronic device is China, for purposes of marking, as well as for applying current trade remedies under the 301 tariffs, IEEPA tariffs, and reciprocal tariffs. 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