The country of origin of a wireless charger

N316680 January 14, 2021 OT:RR:NC:N2:220 CATEGORY: Origin Rosa Zhou D and S Industries (Philippines) Corporation Unit 1-5 Orient Goldcrest Suntrust Ecotown, Bldg. 2 Cavite Philippines RE: The country of origin of a wireless charger Dear Ms. Zhou: In your letter dated December 30, 2020 you requested a country of origin ruling. The merchandise under consideration is referred to as a Ultra Mini Magnetic Wireless Charger (Wireless Charger), Model Number WD-254B, which is described as an inductive type charger for a personal electronic smart watch. The Wireless Charger is comprised of a plastic molded housing, a printed circuit board assembly (PCBA), and a USB Type A connector that are of Philippine origin, and a charging module of Chinese origin. In use, the Wireless Charger is plugged into a USB socket to receive power, and a smart watch is placed in alignment to inductively charge the device. Based on the information provided, the assembly operations in the Philippines consist of soldering a single resistor, the charging module, and the USB connector onto a bare PCB. The PCBA is then assembled into the housing, the chargers are tested, and then packaged. The PCBA serves as a connection point and base for the charging module, while the charging module emits the inductive field that charges an electronic smart watch. The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. The “country of origin” is defined in 19 CFR 134.1(b) 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' within the meaning of this part.” 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, 69 C.C.P.A. 151 (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). Regarding the country of origin of the Wireless Charger, in our view the assembly operations performed in the Philippines, which consists of soldering the charging module onto the PCBA and then assembling them into a plastic housing, does not substantially transform the charging module into a new and different article. Further, it is the opinion of this office that the charging module provides the essence of the device because it is the article within the assembly that is performing the inductive charge function, while the PCBA containing a single resistor is merely providing the electrical connection for the module to the USB socket. Therefore, based upon the facts presented, the Ultra Mini Magnetic Wireless Charger, Model Number WD-254B, is considered a product of China for origin and marking purposes at time of importation into the United States. This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division