The country of origin of rechargeable compact inspection cameras

N355934
December 3, 2025
OT:RR:NC:N2:208
CATEGORY: Origin GreatStar Industrial USA, LLC Jin Fay 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of rechargeable compact inspection cameras Dear Ms. Fay: In your letter dated November 11, 2025, you requested a country of origin ruling on behalf of Great Star Industrial USA, LLC. The merchandise under consideration is the Kobalt™ brand rechargeable compact inspection camera, model number 5982649. These battery-operated cameras are designed for the visual inspection of confined spaces. They permit users to observe hidden areas and are generally used for pipe maintenance, automotive mechanical diagnostics, internal wall inspections, and equipment maintenance. The control and keypad printed circuit board assemblies (PCBAs) are manufactured in Vietnam from Chinese-sourced components. The fabrication of both PCBAs is completed in Vietnam using surface mount technology (SMT) processes. The SMT process consists of pre-production preparation, stencil preparation and solder paste printing, automated component placement, reflow soldering, and testing, which creates fully functioning control and keypad PCBAs. Once the PCBAs are fully functional, they are shipped to China. In China, the main control engine PCBA is programmed via a TF card. This step allows for firmware updates and calibration. After the PCBAs are tested, the final assembly takes place, including affixing the PCBAs to the other Chinese components, such as the display, shell, buttons, etc., to create the finished inspection camera. 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 both PCBAs, which are manufactured in Vietnam, impart the core character of the finished devices, as they provide the essential electrical functionality of the finished inspection cameras. Additionally, the assembly process performed in China would not substantially transform the PCBAs of Vietnamese origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the country of origin of the subject cameras is Vietnam. 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