The country of origin of three pairs of USB wired headsets

N362020June 8, 2026OT:RR:NC:N2:209
CATEGORY: OriginAnsel LoSpeed Tech Corp.No.568, Sec.1, Mingsheng N. Road, Guishan DistrictTaoyuan City 333016TaiwanRE: The country of origin of three pairs of USB wired headsetsDear Mr. Lo:In your letter dated
June 3, 2026
, you requested a country of origin ruling on three pairs of universal serialbus (USB) wired headsets.The items concerned are three pairs of wired headphones referred to as HP Poly Mission 425 USB (D3+Stereo, item# CO1B5AA#AC3), HP Poly Mission 615 USB (D4 Mono, item# CO1C5AA#AC3), and HPPoly Mission 625 USB (D4 Stereo, item# CO1C8AA#AC3), which are all Hewlett Packard (HP) products,corresponding to their 400 and 600 series of wired headphones.The D3+ Stereo is described as a lightweight, stereo (double ear) USB wired headset with a microphone. Theheadset 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 printedA. The completedcircuit board assembly (PCBA), the left main board PCBA, and the right main board PCBPCBAs are tested for functionality, then the speaker assembly and inline box assembly are manufactured andtested. The completed PCBAs, speaker assemblies and inline box assemblies are then shipped to Vietnam.In Vietnam, the boom mcrophone is assembled and inserted onto the headbandi and then the final mechanicalThe finished wired headphones are tested, have their final inspection, packaged, andassembly takes place. shipped to the United States for retail sale.The D4 Mono is described as a lightweight, monaural (single ear) USB wired headset featuring twomicrophones and artificial intelligence (AI) noise reduction. This headset connects to its intended device viaa corded USB-C cable (with USB-C to USB-A adapter attached) and incorporates an inline controller on thecable.
In Taiwan, components originating from China, Taiwan, and the United States are placed and soldered ontobare PCBs via SMT, forming the inline box PCBA and the right main board. The completed PCBAs arehetested for functionality, then the speaker assembly and inline box assembly are manufactured and tested. Tcompleted PCBAs, speaker assemblies and inline box assemblies are then shipped to Vietnam.In Vietnam, the boom microphone is assembled and inserted onto the headband and then the final mechanicalThe finished wired headphones are tested, have their final inspection, packaged, andassembly takes place. shipped to the United States for retail sale.The D4 Stereo is described as a lightweight, stereo USB wired headset featuring two microphones and AInoise reduction. This headset connects to its intended device via a corded USB-C cable (with USB-C toUSB-A adapter attached) and incorporates an inline controller on the cable.In Taiwan, components originating from China, Taiwan, and the United States are placed and soldered ontoPCBA and the Right Main Board PCBA.PCBs via SMT, forming the inline box PCBA, the left main board ,The completed PCBAs are tested for functionality, then the speaker assembly and inline box assembly aremanufactured and tested. The completed PCBAs, speaker assemblies and inline box assemblies are thenshipped to Vietnam.In Vietnam, the boom microphone is assembled and inserted onto the headband and then the final mechanicalThe finished wired headphones are tested, have their final inspection, packaged, andassembly takes place. shipped 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, andinline 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, since substantialtransformation does not occur as a result of the processes performed in Vietnam, the country of origin for theHP Poly Mission 425 USB (D3+ Stereo, item# CO1B5AA#AC3), HP Poly Mission 615 USB (D4 Mono,item# CO1C5AA#AC3), and HP Poly Mission 625 USB (D4 Stereo, item# CO1C8AA#AC3) Headsetswould be Taiwan for marking purposes and for the purposes of applying current trade remedies andadditional 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