The country of origin of a radio remote control apparatus

N355396
November 21, 2025
OT:RR:NC:N2:208
CATEGORY: Origin Joe Castillo Razer (Asia-Pacific) Pte. Ltd. 1 One-North Crescent #02-01 Singapore 138538 RE: The country of origin of a radio remote control apparatus Dear Mr. Castillo: In your letter dated October 29, 2025, you requested a country of origin ruling. The merchandise under consideration is the Razer Wolverine V3 Pro 8K PC controllers, model numbers RZ06-05540100-R3U1 and RZ06-05540200-R3U1. These are 2.4 GHz wireless radio frequency (RF) gaming remote controllers for a personal computer (PC). These RF remote controllers are imported with a wireless USB Type-A dongle and are only compatible with PCs. Additionally, they are rechargeable via a USB Type-A to USB Type-C cable. According to the information provided, both controller models contain a printed circuit board assembly (PCBA) manufactured in Thailand via a surface mount technology (SMT) process utilizing components sourced from various countries. The SMT process includes adhering integrated circuit (IC) chips, such as transistors, resistors, capacitors, etc., to a bare printed circuit board (PCB). All major controller functions are enabled by the finished PCBA, including registering player input during gameplay. The functional PCBA will be sent from Thailand to China for final assembly. The final assembly in China consists of placing the completed PCBA into a shell/casing and attaching components such as brackets, buttons, a directional pad, thumb sticks, a connector, grips, a battery, etc. Lastly, the finished game controllers will be inspected, tested, labelled, and packaged in China. 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 information provided, it is the opinion of this office that the PCBA contributes to the main functionality of the finished radio remote controllers. The complex SMT manufacturing production of these PCBAs, which includes the placement of numerous individual components onto a bare PCB, creates functional PCBAs that result in a substantial transformation of the components to produce PCBAs of Thailand origin. Additionally, the assembly process performed in China would not substantially transform the PCBA of Thailand origin 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 for the V3 Pro 8K PC Controllers, model numbers RZ06-05540100-R3U1 and RZ06-05540200-R3U1, to be Thailand. 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division