The country of origin of desktop personal computers

N349285 June 9, 2025 OT:RR:NC:N2:220 CATEGORY: Origin John McKenzie Baker & McKenzie LLP 101 California Street San Francisco, CA 94111 RE: The country of origin of desktop personal computers Dear Mr. McKenzie: In your letter dated May 21, 2025, you requested a country of origin ruling on behalf of your client, Acer, Inc. The merchandise under consideration is described as four models of automatic data processing (ADP) machines that you refer to as personal computers (PCs). The first PC is identified as the Chromebox Desktop Computer (Chromebox PC), Model Number CXM1, which is described as a 16 cm by 12 cm by 3 cm enclosure containing the motherboard printed circuit board assembly (PCBA) motherboard, system memory, solid state storage (SSD), and a heat sink. The Chromebox PC has multiple USB connection ports, two HDMI ports, and an RJ45 Ethernet port. In your submission, you state that the Chromebox PC’s motherboard PCBA is manufactured in Thailand by a surface mount soldering process of integrated circuits, diodes, capacitors, resistors, etc. onto a bare printed circuit board. Also in Thailand, the processor, memory, and SSD, which are all produced in Taiwan, are added to the motherboard PCBA. After testing, the motherboard PCBAs is then shipped to China where the heat sink, gaskets, a CMOS battery, and a wireless antenna are added and the assembly is inserted into the housing. Following the assembly of the Chromebox PC, it is tested, the operating system (OS) is installed, and the devices are prepared for export to the United States. The second PC under consideration is identified as the Mini PC Desktop Computer (Mini PC), Model Number N1502G-LNL, which is described as a 16 cm by 12 cm by 3 cm enclosure containing the motherboard PCBA, system memory, SSD, and a heat sink. The Mini PC has multiple USB connection ports, two HDMI ports, and an RJ45 Ethernet port. In your submission, you state that the Mini PC’s motherboard PCBA is manufactured in Vietnam by a surface mount soldering process of integrated circuits, diodes, capacitors, resistors, etc. onto a bare printed circuit board. Also in Vietnam, the processor, memory, and SSD, which are all produced in Taiwan, are added to the motherboard PCBA. After testing, the motherboard PCBAs is then shipped to China where the heat sink, gaskets, a CMOS battery, and a wireless antenna are added and the assembly is inserted into the housing. Following the assembly of the Mini PC, it is tested, the OS is installed, and the devices are prepared for export to the United States. The third PC under consideration is identified as the Tower Desktop Computer (Tower PC), Model Number XC-1785, which is described as a 10 cm by 33 cm by 30 cm enclosure containing the motherboard PCBA, system memory, SSD, optical drive, graphics processing unit, and a 300W power supply. The Tower PC has multiple USB connection ports, two HDMI ports, audio jacks, and an RJ45 Ethernet port. In your submission, you state that the Tower PC’s motherboard PCBA is manufactured in Thailand by a surface mount soldering process of integrated circuits, diodes, capacitors, resistors, etc. onto a bare printed circuit board. Also in Thailand, the Taiwan origin processor is mounted to the motherboard PCBA. After testing, the motherboard PCBA is then shipped to China where the Tower PC is fully assembled by adding the memory, SSD, cooling fans, power supply, etc. into the housing. Following the assembly of the Tower PC, it is tested, the OS is installed, and the devices are prepared for export to the United States. The fourth PC under consideration is identified as the All-in-One Desktop Computer (AIO PC), Model Number C24-2YE13I3UNL, which is described as a 54 cm by 16 cm by 42 cm enclosure containing the motherboard PCBA, 24” IPS touchscreen enabled LED display, system memory, SSD, optical drive, graphics processing unit, web cam, and speakers. The AIO PC has multiple USB connection ports, one Display Port, one HDMI port, audio jacks, and an RJ45 Ethernet port. In your submission, you state that the AIO PC’s motherboard PCBA is manufactured in Vietnam by a surface mount soldering process of integrated circuits, diodes, capacitors, resistors, etc. onto a bare printed circuit board. Also in Vietnam, the Taiwan origin processor is mounted to the motherboard PCBA. After testing, the motherboard PCBA is then shipped to China where the AIO PC is fully assembled by incorporating the motherboard PCBA, memory, SSD, cooling fans, power supply, etc. into the housing. Following the assembly of the Tower PC, it is tested, the OS is installed, and the devices are prepared for export 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 origin of the subject PCs, the assembly of the PCBA in Vietnam/Thailand, as noted above, by soldering individual components of various origins onto a bare printed circuit board results in a substantial transformation of those components to produce a motherboards of Vietnam/Thailand origin. Furthermore, it is the opinion of this office that the motherboard PCBA establishes the function of the PC because it is the article within the assembly that houses and controls the interconnection of the processor CPU, memory, and contains the BIOS that enables the ADP machine to function. Lastly, the assembly work conducted in China, which entails basic assembly by inserting, plugging, fastening, etc. does not substantially transform the motherboard PCBA into a new and different article. As a result of the forgoing, we find that the Chromebox Desktop Computer, Model Number CXM1, and the Tower Desktop Computer, Model Number XC-1785, are considered products of Thailand for origin purposes at time of importation into the United States. Likewise, the Mini PC Desktop Computer, Model Number N1502G-LNL, and the All-in-One Desktop Computer (AIO PC), Model Number C24-2YE13I3UNL, are considered products of Vietnam 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 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, (for) Steven A. Mack Director National Commodity Specialist Division