The country of origin of a Strobe Light Animator Build Box

N350222 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 Strobe Light Animator 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 “Strobe Light Animator 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: a geared DC motor, four pieces of 3mm plywood, one piece of 6mm plywood, eight pieces of acrylic etched with images, 45 pieces of 3mm acrylic figures, two pieces of cardboard, a 2-cell AA battery pack, two AA batteries, an LED strip, a 2mm acrylic color wheel, two Y-splitter wires, 32 silicone O-rings, a piece of cardstock, a plastic hinge, four pieces of double sticker EVA foam, seven pieces of elastic, three rivets, and a plastic porthole. The motors will originate in Japan, the Republic of Korea, Taiwan, or Vietnam, and the remaining components will originate in China. In the future, the importer may source the LED strip from the same countries as the motors. The Strobe Light Animator operates by a system in which a platform holding the acrylic etched images spins. When viewed through the porthole, light generated by the LED strip reflects off the etched images on the spinning platform to create animated lighted images. The Strobe Light Animator is a thaumatrope. The spinning of the platform and the reflection of the LED light creates the illusion of a moving squirrel at around 16 frames per second. ISSUE: What is the country of origin of the Strobe Light Animator 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 Strobe Light Animator Build Box is the country of origin of the motor (i.e., Japan, the Republic of Korea, Taiwan, or Vietnam). We agree in part. The subject good contains the components of an unassembled Strobe Light Animator, including the generic motor. 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 Strobe Light Animator’s character or use. Rather, they work in conjunction with other components (e.g., plywood, etched acrylic plates) to enable the operation of the good. Packaging the components of the Strobe Light Animator 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 Strobe Light Animator 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 the LED strips 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