The country of origin of an AI hub

N361412May 27, 2026OT:RR:NC:N2:212
CATEGORY: Classification; OriginHyunwoo KimSorcerics Korea Inc.44-1, Teheran-ro 83-gil, Gangnam-guSeoul 06166South KoreaRE: The country of origin of an AI hubDear Mr. Kim:In your letter, dated
May 10, 2026
, you requested a tariff classification and country of origin determinationruling.The merchandise under consideration is identified as the SOL Artificial Intelligence (AI) Hub, which isfurther described as an AI-powered smart home control device. The subject device is comprised of aSystem-on-Chip (SoC) board, which contains a central processing unit (CPU), within a plastic housing. Onthe outside of the enclosure, there are two camera modules, a speaker, and LED indicator lights. The hub ismeant to be placed on a flat surface within a room or mounted onto the wall.In use, the device functions as an AI-powered control device by wirelessly connecting to the smart devicesthroughout a home or room, such as lights, thermostats, speakers, and more. The camera modules on thedevice “see” the activity in the room and the onboard AI then makes decisions based on the activity that itperceives. These decisions include dimming lights and adjusting the room temperature. You state that thesedecisions are made autonomously and do not need intervention from the user.In your request, you state that the manufacturing process occurs in Korea using components sourcedexclusively from China. This process begins with the programming of the Chinese SoC with the AI software.The camera modules are then attached to the board via USB cables prior to heatsinks being installed onto theboard. A fan and LED module are then attached to the board along with the speaker unit. The plasticenclosure is then assembled around the components before the finished device is calibrated, tested, andpackaged for shipment to the U.S.Classification:You suggest that the correct classification for the subject hub should be 8543.70.9860, Harmonized TariffSchedule of the United States (HTSUS). We agree.
The applicable subheading for the SOL AI Hub will be 8543.70.9860, HTSUS, which provides for“Electrical machines and apparatus, having individual functions, not specified or included elsewhere in thischapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” The general rate of dutywill be 2.6% ad valorem.Country of Origin: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 upon the facts presented, it is the opinion of this office that the SoC board imparts the character of thefinished product. Further, all of the components involved in the manufacture of the device originate fromChina and, in our view, the assembly process is not significantly complex in order to effect a substantialtransformation. As such, the country of origin for the SOL AI Hub will be China.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 Luke LePage at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division