The Country of Origin of the Robotic Vacuum Cleaner

N310020 February 25, 2020 MAR-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Ms. Paula Connelly Sandler, Travis & Rosenberg, P.A. 100 Trade Center, Suite G-700 Woburn, Massachusetts 01801 RE: The Country of Origin of the Robotic Vacuum Cleaner Dear Ms. Connelly: This is in response to your letter dated February 21, 2020, on behalf of your client iRobot Corporation, requesting a country of origin determination on a vacuum cleaner. The merchandise under consideration is identified as the i7 Navigating Robotic Vacuum Cleaner, which includes the i7 Roomba® vacuum robot and the accessories of a rechargeable battery, a bin filter, a dock and line cord, an auto evacuation dock and line cord, a docking station for recharging and a power cord. All these accessories are of Chinese origin and specifically intended solely for use with the i7 Roomba® vacuum cleaner. The Roomba® robot may also include an optional accessory known as a “Virtual Wall®,” a device that contains the robotic vacuum within a certain space. At the time of importation, the i7 Roomba® vacuum robot and accessories will be packaged for retail sale to the ultimate purchaser. The i7 Roomba® vacuum robot is a Wi-Fi connected mapping and navigating vacuum robot used to clean floors. It consists of the navigation module and the mobility module that will be made in Malaysia, and the following modules, assemblies and parts from China: the side brush motor, wheel module, cleaning head, debris bin, plastics and rubber, light touch assembly, cliff harness assembly, ground sensor, and plastic shells and faceplates (housings for the various modules). The navigation module and the mobility module are each primarily made of a circuit board assembly (PCBA) and other electrical components. The bare printed navigation circuit board and 378 electrical components will be imported into Malaysia where the electrical components will be soldered onto the bare board for the navigation module in the surface-mount technology (SMT) process. The camera is then populated on the board assembly and extensive testing and calibration is performed on the module. The bare printed mobility circuit board and 786 electrical components will be imported into Malaysia where the electrical components will be soldered on to the bare board for the mobility module in the SMT process. The module then undergoes programming, calibration and testing. The navigation module and the mobility module will be then assembled with the Chinese origin side brush motor, wheel module, cleaning head, debris bin, plastics and rubber, light touch assembly, cliff harness assembly, ground sensor, and plastic shells and faceplates by soldering, screwing and connecting of electrical wiring and interfaces. The robot then undergoes programming, calibration, and testing prior to being finally configured, labeled, readied for packing, and packed into the retail and master packaging. The provided assembly and test-step flow charts indicate that the manufacturing process in Malaysia has over 70 distinct steps of assembling and testing involving skilled workers, technicians and engineers. You state that the two significant modules which govern the behavior and performance of the product are the navigation module and the mobility module. The navigation module is considered the brains of the robot vacuum, consisting of a main processor, secondary signal processors, memory devices and wireless connectivity hardware. Functions include path planning, map creation, localization and docking. The i7 robot intelligently maps and remembers multiple floor plans to clean an entire home. The patented iAdapt® 3.0 technology with vSLAM® navigation actively captures thousands of precise measurements each millisecond to optimize coverage. In addition, Imprint™ Smart Mapping enables the robot to learn, map and adapt to a home, allowing the user to choose which rooms are cleaned and when. The i7 Robot can be operated by a user’s phone with a downloaded iRobot app. The mobility module acts as the central nervous system for the i7 robot. It is composed of a mobility processor, safety processor, and motor drivers to which all end effectors are connected. These include wheel modules, a side brush, a vacuum motor, and a cleaning head. It also connects, interprets, and drives all sensory systems such as wall follow, light touch, docking, cliff-detection, and floor tracking sensor systems. You further state that the i7 Roomba® vacuum robot consists of over 1,700 components. The navigation module and the mobility module, manufactured in Malaysia, together consist of over 1,150 electrical components and undergo significant post-production testing. These modules include over 67% of all components used in the vacuum robot. In addition, several module subassemblies will be assembled onto the chassis and tested during production in Malaysia. Each of these modules will communicate with the navigation and mobility modules and will be connected directly to the mobility module. These modules cannot function until they are tested and programmed with the applicable software in Malaysia. The labor costs in Malaysia associated with the production of the navigation and mobility modules manufacturing, programming, testing and assembly with Chinese origin modules represents 76% of the total production costs. The remaining 24% occurs in China. Section 134.1(b), Customs Regulations (19 C.F.R. § 134.1(b)), defines "country of origin" as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin”. In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, CBP considers the totality of the circumstances and makes such determinations on a case-by-case basis. The country of origin of the item’s components, extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, and use are primary considerations in such cases. Additionally, factors such as the resources expended on product design and development, the extent and nature of post-assembly inspection and testing procedures, and worker skill required during the actual manufacturing process will be considered when determining whether a substantial transformation has occurred. No one factor is determinative. In light of the above, we find that the key modules are made in Malaysia and the imported components become integral parts of the i7 Roomba® vacuum robot in the manufacturing process. The manufacturing operations in Malaysia create a new and different article of commerce with a distinct character and use that is not previously inherent in the Chinese components. Therefore, the "product of" requirement has been satisfied. The country of origin of the imported i7 Navigating Robotic Vacuum Cleaner is Malaysia. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division