The country of origin of radio remote control apparatus

N362461
July 8, 2026
OT:RR:NC:N2:208
CATEGORY: Origin Brian Murphy Miller & Company P.C. 4929 Main Street Kansas City, MO 64112-2631 RE: The country of origin of radio remote control apparatus Dear Mr. Murphy: In your letter dated June 19, 2026, on behalf of your client, Horizon Hobby, LLC, you requested a country of origin ruling. The merchandise under consideration is radio control transmitters, model NX7e+ Black/White (item numbers: SPMR7110 and SPMR7120). These handheld radio controllers are used to remotely control toy airplanes from a distance via 2.4GHz radiofrequency signals. The radio control transmitters are each comprised of over 100 unique components, which are manufactured in a variety of countries. As per the information provided, the two printed circuit board assemblies (PCBAs) that provide electronic controls for the subject radio remote controls will be produced in the United States using surface mount technology (SMT), dual in-line package (DIP), and wave solder processes. These processes include populating a printed circuit board (PCB) with various electronic components, such as resistors, capacitors, fuses, radiofrequency (RF) chips, through solder paste application and inspection, pick-and-place component mounting and inspection, reflow, soldering and inspection, x-ray inspection, through-hole assembly, cleaning, firmware loading, testing, inspection, packaging, and traceability. Moreover, the two main PCBAs are responsible for RF transmission, reception, and analog to digital processing. The fully functional PCBAs are shipped to China for final assembly. The final assembly takes place in China. This process includes screwing and snapping the plastic housing together, screwing and soldering the gimbals or sticks with wire harnesses, soldering and pressing cables and switches into the housing, screwing the liquid crystal display (LCD) screen into the plastic housing, and attaching the cables. Next, the PCBAs are physically installed into plastic housing, and the antenna is attached. Then, the user interface software, the vibrator motor, the speaker, and the battery are installed. Lastly, the decals are applied, and the final product is tested and packaged. 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). Based on the information provided, it is the opinion of this office that the PCBAs contribute to the main functionality of the finished radio remote transmitters. The complex SMT manufacturing production of these PCBAs, which includes the placement of numerous individual components onto a bare PCB, creates functional PCBAs that result in a substantial transformation of the components to produce PCBAs of U.S. origin. Additionally, the assembly process performed in China would not substantially transform the PCBAs of U.S. origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, we find that the country of origin for these radiofrequency (RF) remote control transmitters, models NX7e+ Black/White (items: SPMR7110 and SPMR7120) is 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) James P. Forkan Director National Commodity Specialist Division