The country of origin of a streaming controller

N362235
June 24, 2026
OT:RR:NC:N2:212
CATEGORY: Origin Joe Castillo Razer (Asia-Pacific) Pte. Ltd. 1 One-North Crescent #02-01 Singapore 138538 Singapore RE: The country of origin of a streaming controller Dear Mr. Castillo: In your letter dated June 11, 2026, you requested a country of origin ruling. The merchandise under consideration is identified as the Razer Stream Controller X, model number RZ20-04790100-R3U1, which is further described as an all-in-on customizable desktop keypad. The subject device is comprised of a printed circuit board assembly (PCBA) within an enclosure. On the front of the enclosure there are 15 programmable LCD membrane buttons. The device is further equipped with USB connection points. In use, the device is attached to a PC, or other computer, allowing the user to manage and control streaming content. The membrane buttons can be programmed with shortcuts for streaming, editing, music production, among a variety of others. These can control the applications, lights, audio, and other functions within the PC via the programmable buttons, which will display the appropriate icon via the LCD. In your request, you state that the manufacturing process begins with the creation of the PCBA, via surface mount technology (SMT), in Thailand. The individual components, such as integrated circuits, switches, transistors, etc., are mounted onto the board and soldered in place. This creates the finished PCBA, which contains the main processor and controls the device operation and functionality. The finished PCBA is then sent to China where it is placed within the enclosure and the keypad is attached. The finished device is then inspected, tested, and packaged for shipment to 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 origin of the subject keypad, it is the opinion of this office that the PCBA imparts the character of the finished device as it incorporates the core functionality of the finished device. Further, the processes performed in China are simple in nature and would not substantially transform the Thai PCBA into a new and different article of commerce. As such, the country of origin of the Razer Stream Controller X, model number RZ20-04790100-R3U1, will be Thailand. 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 Luke LePage at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division