The country of origin of a Mechanical Keyboard (finished product version)

N356462
December 12, 2025
OT:RR:NC:N2:208
CATEGORY: Origin Xiao Yan 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 (finished product version) Dear Ms. Yan: In your letter dated November 26, 2025, you requested a country of origin ruling for a Mechanical Keyboard (finished product version), on behalf of your client, Wooting Store B.V. The merchandise under consideration is identified as the Wooting 60HE+ Mechanical Keyboard, W05T011 (finished product version). The W05T011 (finished product version) comes packaged with the Wooting 60HE+ keyboard, USB-C cable, keycap puller, strap, two spare lekker switches, two spare screws, blister (dust cover), and a postcard. Based on the information provided, the subject finished mechanical keyboard is made up of individual components, such as a microcontroller, hall-effect sensors, switches, a printed circuit board (PCB), a plastic housing, stabilizers, and other subassemblies, which are sourced globally. In Taiwan, the various components are placed onto the PCB using solder paste application, surface mount technology (SMT), and through-hole assembly, creating a complete printed circuit board assembly (PCBA). Firmware is then added and validated. The mechanical assembly of the keyboard housing, stabilizers, and case takes place next. The finished keyboard is then tested and packaged for export. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous

place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Based on the facts presented, it is the opinion of this office that the origin of the finished mechanical 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. As a result, we find that the country of origin for marking and trade remedy purposes of the Wooting 60HE+ Mechanical Keyboard, W05T011 (finished product version), is 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division