The country of origin of gaming laptops

N349899 July 1, 2025 OT:RR:NC:N2:208 CATEGORY: Origin Joe Castillo Razer Asia Pacific Pte Ltd 1 One-North Crescent #02-01 Singapore 138538 RE: The country of origin of gaming laptops Dear Mr. Castillo: In your letter dated June 6, 2025, you requested a country of origin ruling on five models of gaming laptops. The merchandise under consideration is identified as five models of automatic data processing (ADP) machines that you refer to as Razer Blade 16 Gaming Laptop personal computers (PCs), models RZ09-05287EN3-R3U1, RZ09-05288EN3-R3U1, RZ09-05288EN4-R3U1, RZ09-05289EN4-R3U1, and RZ09-05289EN9-R3U1, which are all laptops equipped with Windows 11 Home NexGen Premium Edition operating system and Razer Synapse. All models have three USB Type-A ports, two USB4 Type-C Ports, one MicroSD card reader (UHS-II), and one HDMI 2.1 output. Moreover, each model in question has the same appearance, but has variations in the processor speed, memory size, GPU type, and storage capacity, based on the model configurations. In your submission, you state that the manufacturing process for all five models of the Razer Blade 16 gaming laptops is the same. The motherboard PCBAs are assembled in Vietnam using components sourced from various countries of origin. The production of the PCBA starts with a blank printed circuit board (PCB) and advances through many steps, using surface mount technology (SMT), laser etching, solder paste application, accurate pick and placement of the components through a reflow oven, and auto-inspection and testing of the parts. Once the motherboard PCBA is tested and completed, it is then shipped to China where the Razer Blade 16 gaming laptops are assembled. Each assembly process consists of inserting the PCBA onto the bottom cover and attaching the webcam, OLED panel, wireless antenna, keyboard, fan, lithium battery, etc., into the housing. Lastly, these laptop PCs are inspected, tested, labeled, and are packaged for export into the United States. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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 Razer Blade 16 Gaming Laptop person computers (PCs), the assembly of the motherboard PCBA in Vietnam, via surface mount technology (SMT), laser etching, solder paste application, accurate pick and placement of small components, and permanent connection of the components though a reflow oven results in a substantial transformation of those components to produce a motherboard PCBA of Vietnam origin. Furthermore, it is the opinion of this office that the motherboard PCBA is the dominant component of the laptop 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 permits the ADP machine to function. The assembly work conducted in China, which entails inserting, plugging, and fastening, does not substantially transform the motherboard PCBA into a new and different article. Therefore, we find that the Razer Blade 16, model numbers RZ09-05287EN3-R3U1, RZ09-05288EN3-R3U1, RZ09-05288EN4-R3U1, RZ09-05289EN4-R3U1, and RZ09-05289EN9-R3U1 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 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 Lisa Cariello lisa.a.cariello@cbp.dhs.gov. Sincerely, James Forkan Acting Director National Commodity Specialist Division