The country of origin of a power adapter set

N348029 May 14, 2025 OT:RR:NC:N2:220 CATEGORY: Origin Seqon Lee Tiamo Customs Attorney 49 Parang-Ro Incheon 22770 South Korea RE: The country of origin of a power adapter set Dear Mr. Lee: In your letter dated April 19, 2025, you requested a country of origin ruling on behalf of your client, POPPhone Co., Ltd. The merchandise under consideration is identified as the Safe Ultra-fast Multi-charger (Multi-Charger), which is a retail carton containing a 60W power adapter and a USB-C output cable assembly. The cable assembly is described as a cable with a male USB-C connector on one end and an inline plastic housing where the electrical connections are divided into three output cables having different output formats. You describe the function of the Multi-Charger as allowing multiple phones to be charged simultaneously. In your request, you state that the output cable assembly is manufactured in Korea from parts and materials of Korean origin. The power adapter is said to be manufactured in China and shipped to Korea. In Korea, the power adapter and cable assembly are retail packaged together and exported to the United States. When determining the country of origin, 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 Multi-Charger, in our view the packaging of the power adapter plug and the cable assembly together in a retail carton does not result in a substantial transformation of the Chinese power adapter into a new and different article of commerce with a new name, character, and use. Furthermore, it is the opinion of this office that the power adapter plug imparts the essential character of the retail set. As a result, the country of origin of the Multi-Charger is China upon 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 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