The country of origin of gaming laptops

N357057
December 23, 2025
OT:RR:NC:N2:208
CATEGORY: Origin Joe Castillo Razer (Asia-Pacific) Pte. Ltd. 1 One-North Crescent #02-01 Singapore 138538 Singapore RE: The country of origin of gaming laptops Dear Mr. Castillo: In your letter dated December 15, 2025, you requested a country of origin ruling on five models of gaming laptops. The merchandise under consideration is identified as five models of automatic data processing (ADP) machines that you refer to as Razer Blade 16 Gaming Laptop personal computers (PCs), models RZ09-05817EN3-R3U1, RZ09-05818EN3-R3U1, RZ09-05818EN4-R3U1, RZ09-05819EN4-R3U1, and RZ09-05819EN9-R3U1, which are all laptops equipped with Windows 11 Home NexGen Premium Edition operating system and Razer Synapse. All models utilize the Intel Core Ultra X9 processor 386H. All models have three USB Type-A ports, two USB4 Type-C Ports, one MicroSD card reader (UHS-II), and one HDMI 2.1 output. Moreover, each model in question has the same appearance, but has variations in the memory size, GPU type, and storage capacity, based on the model configurations. In your submission, you state that the manufacturing process for all five models of the Razer Blade 16 gaming laptops is the same. The motherboard printed circuit board assemblies (PCBAs) are assembled in Vietnam using components sourced from various countries of origin. The production of the subassembly PCBA motherboards starts with a blank PCB and advances through many steps completed by various machines to create finished motherboard PCBAs. This production process includes the following steps: surface mount technology (SMT), laser etching, solder paste application, accurate pick and placement of small parts, permanent connection of the parts through a reflow oven, auto-inspection, and testing. Once the motherboard PCBAs are tested and completed, they are then shipped to China where the Razer Blade 16 gaming laptops are assembled. Each assembly process consists of inserting the PCBA into the shell/cover and attaching other parts, such as the display panel, keyboard, storage, Wi-Fi antenna, webcam, cooling fans, touch pad, speaker, battery, into the housing, as well as installing software. Lastly, these laptop PCs are inspected, tested, labeled, and are packaged for export into the United States.

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 country of origin of the Razer Blade 16 Gaming Laptop person computers (PCs), the assembly of the motherboard PCBAs in Vietnam, via surface mount technology (SMT), laser etching, solder paste application, accurate pick and placement of small components, and permanent connection of the components though a reflow oven, results in a substantial transformation of those components to produce fully functioning motherboard PCBAs of Vietnam origin. Furthermore, it is the opinion of this office that the motherboard PCBAs are the dominant component of the laptop PCs. The assembly work conducted in China, which entails inserting, plugging, and fastening, does not substantially transform the motherboard PCBAs into a new and different article. Therefore, we find that the Razer Blade 16, model numbers RZ09-05817EN3-R3U1, RZ09-05818EN3-R3U1, RZ09-05818EN4-R3U1, RZ09-05819EN4-R3U1, and RZ09-05819EN9-R3U1 are considered products of Vietnam for origin purposes at the time of importation into the United States. 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