The country of origin of a multimeter

N350166 July 7, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Chuhao Lan Yingke Law Firm 39F, 501, Yincheng Middle Road, Pudong New District Shanghai 20012 China RE: The country of origin of a multimeter Dear Ms. Lan: In your letter dated June 12, 2025, on behalf of your client, Shanghai SDAR Electronic Instruments Co., Ltd., you requested a country of origin ruling on a multimeter. Descriptive literature was provided for our review. The item under consideration is described as the SDT-830C handheld digital multimeter, which is an electronic instrument that measures AC/DC voltage, current, and resistance. In operation, the user selects the desired measurement function (voltage, current, resistance, etc.) using the rotary dial on the multimeter. The black probe is connected to the common terminal, while the red probe is connected to the appropriate terminal depending on the measurement function selected. To measure the voltage, the multimeter is connected in parallel with the component or circuit being tested. The multimeter measures the potential difference between two points and displays the reading on the LCD screen. To measure the current, the multimeter is connected in series with the circuit so that the current flows through the meter. An internal shunt resistor is used to measure the voltage drop across the resistor, and the current is calculated using Ohm’s Law. To measure the resistance, a known current is forced through the component being measured, and the voltage drop is measured. Ohm’s Law (the relationship between voltage, current, and resistance in an electrical circuit) is then used to calculate the resistance. The SDT-830C, as a digital multimeter, uses an Analog-to-Digital Converter to convert the measured electrical signals into a digital value, which is then displayed on the LCD screen. The SDT-830C is made of a printed circuit board assembly (PCBA), LCD display, rotary selector switch, input and output jacks, and a molded plastic housing. Once fully assembled, the device is used by electricians and technicians for precision electrical measurements. In Vietnam, the PCBA is constructed using surface-mount technology (SMT). The process involves placing and soldering hundreds of various components onto the printed circuit board (PCB). Bare semiconductor dies are bonded and wire-connected under epoxy encapsulation, and larger through-hole parts are hand-inserted and soldered. Once complete, the software programs are uploaded to the PCBA boards, which are then functionally tested. The completed Vietnamese PCBA is then shipped to China where it is installed into a Chinese-origin plastic housing. Additional Chinese components, including the LCD displays, selector knobs, and connectors are also installed at this time. Finally, silk printing is performed on the final product before packaging and shipping to the United States. When determining the country of origin, 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 country of origin of the SDT-830C handheld digital multimeter, it is our opinion that the assembly process performed in Vietnam is considered complex and results in a substantial transformation of over a hundred different components. The creation of the PCBA in Vietnam using SMT generates a working PCBA capable of performing measurements. It is our opinion that this is a new and different article of commerce with a name, character, and use distinct from the individual components. The incorporation of the PCBA into the plastic housing and adding the dial and LCD screen in China does not change the end use of the PCBA. The multimeter’s core functionalities are firmly established in Vietnam during the circuit board assembly and programming stages and are only enhanced for cosmetic and protective purposes in China. Accordingly, the country of origin of the SDT-830C handheld digital multimeter will be Vietnam, which is where the PCBA creation and programming occurs. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division