The country of origin of a Drawing Machine Build Box

N350221 December 11, 2025 OT:RR:NC:N3:356 CATEGORY: Origin Nick Baker Kroll, LLC 1111 Bagby Street, Suite 1900 Houston, TX 77002 RE: The country of origin of a Drawing Machine Build Box Dear Mr. Baker: In your letter dated June 16, 2025, on behalf of CrunchLabs LLC, you requested a country of origin ruling for purposes of additional trade remedy measures. A description and sample of the subject good were submitted in connection with your inquiry. FACTS: The good under consideration is identified as the “Drawing Machine Build Box.” It is an unassembled kit for children ages 8-12 that includes all necessary components to assemble the good. All components are imported into the United States packaged together in a retail box. The individual components are: twin generic 1.5V DC motors, two motor wheels, nine pieces of plywood (one of which is backed with adhesive), a battery pack, an AA battery, a multicolor ballpoint pen, a pen holder, 10 sheets of paper, EVA foam stickers, four rivets, two Y-splitter wires, four rivets, four M5 bolts, four pieces of T-aglet elastic, hook-and-loop closures, and a wooden bead. The motors will originate from Japan, the Republic of Korea, Taiwan, or Vietnam, and the remaining components will originate from China. In the future, the importer may source a portion of the plywood pieces from the same countries as the motors. The drawing machine operates via a linkage system in which pivoting wooden bars direct the machine’s movement. The linkage “arms” are connected to two separate wheels that spin at slightly different speeds. The arms are joined at the other end, and at the connection point a pen is secured in place. The arms guide the pen’s movement across a piece of paper, creating a repeating pattern that results in a drawing. The arms can be adjusted to create different drawings. ISSUE: What is the country of origin of the Drawing Machine Build Box for purposes of additional trade remedy measures? LAW AND ANALYSIS: When determining the country of origin for purposes of applying current trade remedies under Section 301, as well as 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). Packaging alone is not a substantial transformation. See Headquarters Ruling Letter (“HQ”) 733729, dated January 2, 1001, which concluded that packaging teas in Singapore did not result in a substantial transformation, as there was no change in the name, character, or use of the imported teas. In your letter, you assert that the country of origin of the Drawing Machine Build Box is the country of origin of the two motors (i.e., Japan, the Republic of Korea, Taiwan, or Vietnam). We agree in part. The subject good contains the components of an unassembled drawing machine, including the two generic motors. As noted above, the motors will be of Japanese, Korean, Taiwanese, or Vietnamese origin, and the remaining components will be of Chinese origin. The generic motors are general-purpose articles that do not define the drawing machine’s character or use. Rather, they work in conjunction with other components (e.g., linkage arms, battery pack, battery) to enable the operation of the good. Packaging the components of the drawing machine in China will not transform any of the components into articles with a new name, character, or use; each component remains a distinct article. HOLDING: In accordance with Headquarters Ruling Letter H350263, dated October 3, 2025, for purposes of additional trade remedy measures, the countries of origin of the Drawing Machine Build Box will be Japan, the Republic of Korea, Taiwan, or Vietnam (the country of origin of the motor) and China (the country of origin of the remaining components). If any of the plywood pieces are sourced from the same country as the motors, the country of origin of these components would be the country from which they originate. 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. A dditionally, 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 Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division