The country of origin of a memory card reader

N346928 April 3, 2025 OT:RR:NC:N2:220 CATEGORY: Origin Stefan Betesh Sakar International Inc 195 Carter Drive Edison, NJ 08817 RE: The country of origin of a memory card reader Dear Mr. Betesh: In your letter dated March 19, 2025, you requested a country of origin ruling. The merchandise under consideration is identified as Memory Card Reader (Reader), PN 625423, which is described as plastic housing having two memory card slots on one end and a short, hardwired cable with an 8-pin digital connector and a USB-C socket on the other end. Internally, the Reader incorporates a printed circuit board assembly (PCBA) and functions to connect the device to mobile devices, tablets, and personal computers. The Reader is retail packaged along with a USB-C to USB-Micro adapter cable assembly. In your request, you state that the Reader is assembled in Vietnam by inserting the PCBA into the plastic housing, soldering the 8-pin connector onto one end of the raw cable and the other end onto the PCBA. Aside from the raw cable and the USB-C to USB Micro adapter cable assembly, which are of Vietnamese origin, all the parts are manufactured in China. When determining the country of origin for purposes of applying current trade remedies under Section 301, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). Regarding the country of origin of the subject Reader, in our view, the assembly work described as occurring in Vietnam, which consists of inserting the Chinese origin PCBA into the housing, soldering the connectors and wires onto the PCBA does not substantially transform the PCBA into a new article. Furthermore, it is the opinion of this office that the PCBA, which functions to read the memory cards and communicate with the personal electronic devices, establishes the function of the finished Reader. As a result, we find that the Chinese origin PCBA is not substantially transformed in Vietnam into a different article of commerce with a new name, character, or use.? Thus, the Memory Card Reader, PN 625423, is considered a product of China for origin purposes at the time of importation into the United States. 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. Importations of this product may be subject to the provisions of Section 133 of the Customs Regulations if they copy or simulate a registered trademark, trade name or copyright recorded with U.S. Customs and Border Protection.? If you are an authorized importer of the product we recommend notifying your local Customs office prior to importation. 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division