The country of origin of a digital blood pressure monitor

N350225 July 17, 2025 CATEGORY: Origin Tirta Halim T Customs Broker, Inc. 5777 W. Century Blvd. #965 Los Angeles, CA 90045 RE: The country of origin of a digital blood pressure monitor Dear Mr. Halim: In your letter dated June 16, 2025, you requested a country of origin ruling on a digital blood pressure monitor on behalf of Fortunit Creative Co., LTD. The product under consideration is an Arm-type Fully Automatic Blood Pressure Monitor (Model # DBP-1359). It consists of a motherboard (chip-on-board/COB), an air pump, a pressure sensor (pressure transducer), two valves, an LCD display, a cuff (composed of an arm cuff, an air tube, and an air plug), a lower cover, an upper cover, and other components. The following components are produced in China: silicone tube, O-type ring, cushion, zebra paper, pressure transducer, 12 cm wire, DC outlet PCB (printed circuit board), button PCB, metal dome, arm-type pump, reeds, screws, arm-type mechanical valve, louder speaker, main PCB, chip (also called Microprocessor Control Unit/MCU, which can be sourced from Taiwan), backlight, and LCD. Cambodia components include: sensor connector, adapter jack label, keys (M, ON/OFF and SET), upper cover, arm solenoid valve, ABS pump fixed film, lower cover, battery cover, arm with socket, PVC tube, 90° four-way gas pipe connector, LCD fixed frame, air plug, arm cuff, and silk screen printed transparent sheets. In Cambodia, the main PCB, MCU, resistors, capacitors, transistors, crystal oscillators, and other electronic components are soldered to form a motherboard using surface mount technology (“SMT”). Chinese-origin software source code is compiled by the Cambodian engineer to generate the firmware file based on the different functions of the order. The firmware file is downloaded to the MCU. The motherboard will be tested to check if it is fully functional. The pressure sensor will be soldered to the motherboard. The LCD and zebra paper are hot pressed using a hot press machine, followed by the motherboard. The motherboard is debugged. The metal dome and button PCB are soldered. The remaining assembly processes involve: the horn wire welding, batter reeds and buzzers (or horn assembly) assembly, pneumatic components (cuff plug, pump, solenoid valve, silicone tube) assembly, lower cover pneumatic components assembly, power socket wire (DC outlet PCB, electric outlet, and wire) soldering, back soldering, COB lower cover assembly, upper cover assembly, upper and lower cover assembly, lower cover screw, transparent sheet assembly, final inspection, and battery cover assembly. The complete device and the cuff are packaged together. 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). Customs and Border Protection (“CBP”) has consistently held that the assembly of components onto a printed circuit board is a substantial transformation. See HQ ruling 735306, dated December 21, 1993, wherein CBP stated: With respect to printed circuit boards, Customs has ruled that the complete assembly of all the components onto a printed circuit board was a substantial transformation of the printed circuit board because the assembly process was complex and involved a considerable amount of skill and time. HQ ruling H301776, dated August 7, 2019, stated “CBP has consistently held that conducting a software build—compiling source code into object code—results in substantial transformation.” You explain that: The essential parts of the digital blood pressure monitor are the COB, pump and cuff. The COB is responsible for driving blood pressure measurement, data calculation and display. The pump is used to press air into the cuff by electricity for measurement. The cuff works by inflating and pressurizing, and it uses sensors to detect the pressure fluctuations when blood flow resumes. Based on the totality of the circumstances, we find that the assembly of the motherboard and programming operations performed in Cambodia substantially transform the Chinese main PCB, MCU, and other components into a product of Cambodia. The Cambodian-origin motherboard and cuff play important roles of the blood pressure monitor. Additionally, the blood pressure monitor is completed in Cambodia through sub-assembly and final assembly. As such, the country of origin for the subject blood pressure monitor will be Cambodia. 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 Fei Chen at fei.chen@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division