Country of origin marking of Smart Glasses; Section 301

HQ H345669 July 23, 2025 OT:RR:CTF:VSP H345669 ACH CATEGORY: Origin Ms. Suzanne Kane Akin Gump Strauss Hauer & Feld LLP 2001 K Street, N.W. Washington, DC 20006-1037 Re: Country of origin marking of Smart Glasses; Section 301 Dear Ms. Kane: This is in response to your correspondences, dated March 6, 2025 and March 20, 2025, requesting a binding ruling on behalf of your client, [ ] concerning the country of origin of two different models of Smart Glasses for marking, and Section 301 duty purposes. Either [ ] or [ ] will act as the importer of record. You have requested that certain information submitted in connection with this request be treated as confidential. Inasmuch as this request conforms to the requirements of 19 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. The information bracketed in your request will not be released to the public and will be withheld from published versions of this ruling. FACTS: 1. [ ] Smart Glasses - Model #1 The Next Generation Smart Glasses addressed in the March 6, 2025 inquiry are artificial intelligence (“AI”) glasses that offer users the opportunity to capture photos and videos, make video calls or livestream, store photos and videos, listen to music, make phone calls, send texts using voice commands, and ask questions and receive answers using AI. The Smart Glasses have a front frame, right and left temple pieces, and two lenses. The lenses of the Smart Glasses are available as prescription or non-prescription, depending on what the customer chooses. The customer has the option to select polarized or non-polarized sunglass lenses, transition, blue filter, or clear form lenses. The Smart Glasses are equipped with a [ ] chipset that is mounted to the main logic board (“MLB”) within the product. The Smart Glasses incorporate a high-power main processing unit that handles heavy computing including photo and video processing, wireless communication, 2 and AI functionalities; a microcontroller unit (“MCU”) that handles lower computing functionalities such as sensor processing, audio playback, and microphone capture; components that provide memory storage; and components that provide capacitive touch functionality, allowing users to interact with the Smart Glasses through touch gestures. All of these functions are made possible by the chipset mounted on the MLB, which is responsible for the flow of data, power, and communication between the major components. The main components of the Chipset include the applications processor, which handles instructions, manages memory, manages power, processes all multimedia, and ensures that all parts and components are communicating with each other to fully integrate operations, and the WiFi/Bluetooth chip, which enables Wi-Fi and Bluetooth connectivity for the device. It is stated that the MLB drives the functioning of the Smart Glasses through visual and audio feedback from several other components, including: ? The Secondary Logic Board (“SLB”) (surface mounted in Vietnam), which is an auxiliary PCBA that is responsible for enabling and amplifying the audio of the speaker on the right temple flexible printed circuit board. The SLB also contains an action button that allows the user to activate video or streaming. The SLB supports the communication capabilities of the Smart Glasses by enabling the speaker to perform key functions by engaging the action button. ? Flexible Printed Circuit Boards (“FPCAs”), which are responsible for connecting the different components of the Smart Glasses to each other and directly or indirectly to the MLB. The Superflex FPCA contains a microphone and connects to the MLB, camera, SLB, and charging contacts. The Camera FPCA contains the camera module and connects to the Superflex FPCA. The Right Temple FPCA contains two microphones, an integrated circuit (“IC”), and right speaker pads and connects to the SLB and the right temple speaker. The left temple FPCA contains two microphones and left speaker pads and connects to the MLB and the left speaker. The Slider FPCA contains a two-position switch and connects to the MLB.