The country of origin of two pairs of USB wired headsets

N361196May 19, 2026OT:RR:NC:N2:209
CATEGORY: OriginJaden KuoPricewaterhouseCoopers Legal25F, No. 333, Section 1, Keelung Road, Xinyi DistrictTaipei 110TaiwanRE: The country of origin of two pairs of USB wired headsetsDear Mr. Kuo:In your letter dated
May 4, 2026
, you requested a country of origin ruling on two pairs of USB wiredheadsets.The items concerned are two pairs of wired headsets referred to as HP Poly Mission 415 USB (D3+ Mono)and HP Poly Mission 825 USB (D6 Stereo), which are both Hewlett Packard (HP) products, corresponding tothe 400 and 800 series, respectively.The D3+ Mono is described as a lightweight, monaural (single ear) USB wired headset with a microphone.This device connects to its intended device via a USB C cable (with USB C to USB A adapter attached) andincorporates an inline control box on the cable.In Taiwan, components originating from China, Taiwan, and the United States are placed and soldered ontobare printed circuit boards (PCBs) via surface mount technology (SMT), forming the Inline Box printedcircuit board assembly (PCBA) and the Right Main Board PCBA.The Inline Box printed circuit board assembly (PCBA) is responsible for the main control and processing functions (i.e., volume, mute, andanswer/end calls) and the Right Main Board PCBA, is the primary electronic circuitry used to interconnectthe boom mic, speaker, and inline box. The completed PCBAs are tested for functionality, then the speakerassembly and inline box assembly are manufactured and tested. The completed PCBAs, speaker assembliesand inline box assemblies are then shipped to Vietnam.In Vietnam, the boom microphone is assembled and inserted onto the headbandthe final mechanical and assembly takes place. The finished wired headphones are tested, inspect, packaged and shipped to theed,United States for retail sale.
The D6 Stereo is described as a lightweight stereo (double ear) USB wired headset with a microphone. Thisdevice connects to its intended device via a USB C cable (with USB C to USB A adapter attached) andincorporates an inline control box on the cable.In Taiwancomponents originating from China, Taiwan, and the United States are placed and soldered onto a, bare PCB via SMT, forming the Inline Box PCBA 6 separatePCBAs (, Left Main Board PCBA, Right Main, two Feedback Microphone (FBMIC) PCBAs, and a Noise Cancelling LED PCBA. TheBoard PCBA(NC) )completed PCBAs are tested for functionality, then the speaker assembly and inline box assembly are createdand tested. The completed PCBAs, speaker assemblies and inline box assemblies are then shipped to Vietnam.In Vietnam, the boom microphone is assembled and inserted onto the headband. The final mechanicalassembly takes place. The finished wired headphones are tested, have their final inspection, packaged, andshipped to the United States for retail sale.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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 various PCBAs, speaker assemblies and,inline box assemblies manufactured in Taiwan are the fundamental functional components of each headset.The PCBAs form the control functions and main electronic circuitry, the speaker provides the essential audiooutput, and the inline box provides complete inline control for the user. Together, they provide the corefunctions of the headsets, providing the essence of the finished product. The assembly operations performedin Vietnam will not change the character and end use of these products. Therefore, ince substantialstransformation does not occur as a result of the processes performed in Vietnam, the country of origin for theHP Poly Mission 415 USB and HP Poly Mission 825 USB Headsets would be Taiwan for marking purposesand for the purposes of applying current trade remedies and additional duties.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Steven Pollichino at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division