The country of origin of a wireless charger

N318108 March 17, 2021 OT:RR:NC:N2:220 CATEGORY: Origin Jane Li 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. Li: In your letter dated March 5, 2021 you requested a country of origin ruling. The merchandise under consideration is identified as the Magnetic Charging Cable (wireless charger) Model WD-254C, 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 charging module, and an insulated electrical cable with a USB Type A connector. In use, the wireless charger is plugged into a USB socket to receive power, and a smart watch is placed in alignment with the module to inductively charge the device. Based on the information provided, the assembly operations in the Philippines consist of stranding and sheathing wire to produce an insulated electrical cable, soldering the charging module and the USB connector onto the ends of the cable, inserting the module into a plastic housing, testing, and packaging. All the components, which include the individual wire strands, the USB connector, the housing, and the charging module, are said to be of Chinese origin. We would note that the charging module is the component within the assembly that emits the inductive field to charge 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 operation performed in the Philippines, which consists of soldering the charging module onto the cable and assembling 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 for the essence of the wireless charger because it is the article within the assembly that is performing the inductive charge function. Therefore, based upon the facts presented, the Magnetic Charging Cable, Model WD-254C, 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