RE: The country of origin of a radio control transmitter

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364774 September 15, 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 a radio control transmitter Dear Mr. Murphy: In your letter dated September 1, 2026, on behalf of Horizon Hobby, LLC, you requested a country of origin ruling. The merchandise under consideration is a radio control transmitter, model No. DX6e, item No. SPMR6655A, which is a handheld remote controller used to remotely control toy airplanes, helicopters, and multirotor aircraft through a 2.4 GHz radio frequency. This radio control transmitter is comprised of components that are manufactured in a variety of countries. According to the information provided, the two key printed circuit board assemblies (PCBAs), the Plano RF Transmitter Module PCBA and the MBA Main Computer PCBA will be manufactured in the United States (U.S.) using surface mount technology (SMT). This process encompasses dual in-line packaging (DIP) and wave soldering, including populating a bare printed circuit board (PCB) with various electrical and electronic components, such as resistors, capacitors, fuses, RF chips, and other components. The Plano RF Transmitter Module PCBA is the main radiofrequency (RF) transmitter for communication with the receiver of the toy car or boat. The MBA Main Computer PCBA is the main computer board responsible for converting analog inputs into digital information to be transmitted by the Plano RF Transmitter Module. Model DX6e also includes an Austin Receiver PCBA, which performs the function of receiving control data at low power from a second transmitter. All non-Chinese components, including the Plano RF Transmitter Module PCBA, MBA Main Computer PCBA, and Austin Receiver PCBA, will be shipped to China for final assembly into the radio control transmitters.
The CBA PCBA, which functions as a serial connection to auxiliary devices; the Roller Wheel Board, which supports the roller wheel, tactile button, and encoder; and the Trim PCB Board, which functions as the board for trim switches, are produced in China. The final assembly also takes place in China. This process involves the following: the Chinese plastic housing will be screwed and snapped together; the gimbals or sticks will be screwed, pressed, and soldered with wire harnesses; cables and switches will be soldered and press-fit into the housing; the Chinese LCD screen will be screwed into the plastic housing and attached to cables; the PCBAs will be installed into the plastic housing; software will be installed; the antenna will be connected; the battery will be installed; decals will be applied; and testing will be performed. Lastly, the radio control transmitter will be packaged and shipped 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). Based on the information provided, it is the opinion of this office that the Plano RF Transmitter Module PCBA and the MBA Main Computer PCBA are the key components of the finished radio remote transmitters, since they convert and transmit RF control signals and communicate with the receiver. The complex SMT process used to manufacture these PCBAs, which includes the placement of numerous individual components onto a bare PCB, creates functional PCBAs and results 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 these 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 goods. As a result, we find that the country of origin of this radio control transmitter, model No. DX6e, item No. SPMR6655A, 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