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 N365050 September 29, 2026 OT:RR:NC:208 CATEGORY: Origin Brian Murphy Miller & Co 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 14, 2026, on behalf of your client Horizon Hobby, LLC, you requested a country of origin ruling. The merchandise under consideration is a radio control transmitter, model iXSR+, item number SPMR6425A, which is a handheld radio remote controller used to control radio-controlled toy cars and boats. This radio controller operates on a 2.4 GHz radio frequency. The subject radio control transmitter is comprised of approximately 100 components that are manufactured in various countries. The two main printed circuit board assemblies (PCBAs) are the Plano RF transmitter module and the MBA main computer PCBA. The Plano RF transmitter module PCBA is used for communication with the receiver of the toy car or boat. The MBA main computer PCBA is the main computer board that converts analog inputs into digital information to be transmitted by the Plano RF transmitter module. The Plano RF transmitter module and the MBA main computer PCBAs are produced in the United States using surface mount technology (SMT) and dual in-line package (DIP)/wave solder processes. These processes involve populating a printed circuit board (PCB) with various electrical and electronic components, including resistors, capacitors, fuses, and radio frequency (RF) chips. The PCBAs are then run through test fixtures to load U.S.-developed firmware, verify functionality, and calibrate RF performance. Model number iXSR+ also includes an Android System-on-Module (SOM) produced in China, which includes an Android touch screen for the user interface and a Wi-Fi/Bluetooth module. According to the information provided, the Android SOM provides the user interface to adjust parameters on the MBA and is not used in the transmission or reception of signals.
All non-Chinese components, including the Plano RF transmitter module PCBA and the MBA main computer PCBA, are shipped to China for final assembly. In China, the following assembly operations will occur to create a complete radio control transmitter: the plastic housing will be screwed and snapped together; the Chinese LCD screen will be screwed into the plastic housing and attached to cables; triggers and wheels will be screwed, pressed, and soldered with wire harnesses; cables and switches will be soldered and press-fit into the housing; the Plano RF transmitter module PCBA and the MBA main computer PCBA will be installed into the plastic housing; and additional software and firmware will be installed. In addition, the Chinese PCBAs for non-RF transmission/reception user control, i.e., throttle, touch panel user interface, and steering potentiometer mechanism, will be assembled into the complete product. Then, the battery and decals will be added, testing will occur, and the complete radio remote controller 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 iXSR+, item number SPMR6425A, is the United States. Whether an article may be marked with the phrase "Made in the USA" or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of marking indicating that an article is made in the USA. 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