The country of origin of a power adapter

N348708 May 29, 2025 OT:RR:NC:N2:220 CATEGORY: Origin Debby 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 power adapter Dear Ms. Li: In your letter dated April 10, 2025, you requested a country of origin ruling on insert The merchandise under consideration is identified as the 20W Dual Port USB C+USB A 3.0 Wall Charger (Power Adapter), Model # AQ0527A, which is described as a rectifier having two female sockets, namely one USB Type-A and one USB Type-C socket, on one side and a two-prong electrical plug on the other end. The Power Adapter is intended to supply power to various types of USB enabled electronic devices. In your submission, you state that the Power Adapter is comprised of materials from China, Taiwan, and the Philippines. The assembly process begins with the manufacturing of a printed circuit board assembly (PCBA) that occurs in the Philippines by soldering multiple components, such as integrated circuits, resistors, capacitors, diodes, a transformer, etc. onto a bare printed circuit board via a surface mount and through-hole insertion process. The PCBA is then attached to a plastic housing by means of ultrasonic welding. The final product undergoes testing and visual inspection before it is packaged in a retail carton for export. 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 Power Adapter, in our view the assembly of the PCBA in the Philippines by soldering the individual components onto the bare board results in a substantial transformation of the components to produce a PCBA of Philippine origin. Furthermore, it is the opinion of this office that the PCBA establishes the function of the electrical charging device because it is the article within the assembly that converts and supplies electricity to electronic devices via the USB sockets. As such, we find that the components that make up the Power Adapter are transformed in the Philippines into a new and different article of commerce with a distinct name, character, and use. Thus, the 20W Dual Port USB C+USB A 3.0 Wall Charger (Power Adapter), Model # AQ0527A, is considered a product of the Philippines 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. 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