The country of origin of a Domino Robot Hack Pack

N350297 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 Domino Robot Hack Pack 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 “Domino Robot Hack Pack.” It is an unassembled kit for teenagers and adults 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 USB power bank, a microcontroller, a bread board, an H-bridge, seven pieces of 3mm plywood, a servo motor, two DC motors, two line sensors, 45 balsa wood dominoes, one piece of 6mm acrylic, 30 pieces of polymer dominoes, a limit switch, a steel weight, seven IM standoffs, electrical tape, 18 10mm bolts, a USB cable, two IM walls, three large O-rings, a sensor mount, nine hex nuts, five more 10mm bolts, three 7mm spacers, two pieces of adhesive-backed 3mm plywood, two wheels, a follower, H-bridge wires, a screwdriver, four 30mm bolts, a steel rod, five 4mm bolts, seven medium O-rings, a punchout card, an EVA foam square, a 22.5mm spacer, two acorn nuts, a servo horn, servo stickers, five plastic washers, and acorn nut tubing. The microcontrollers will originate in Taiwan, Italy, Malaysia, or Vietnam, and the remaining components will originate in China. The Domino Robot Hack Pack is intended to be built primarily for amusement by teenagers and adults who want to learn how to code through the assembly, modification, and operation of the completed item. The Domino Robot is designed to place dominos at regular intervals while following a user-defined path. It comes with default programming and is designed to be “hacked” and re-programmed. ISSUE: What is the country of origin of the Domino Robot Hack Pack 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 Domino Robot Hack Pack is the country of origin of the microcontroller (i.e., Taiwan, Italy, Malaysia, or Vietnam). We agree in part. The subject good contains the components of an unassembled Domino Robot, including the microcontoller. As noted above, the microcontrollers will be of Taiwanese, Italian, Malaysian, or Vietnamese origin, and the remaining components will be of Chinese origin. The microcontrollers are general-purpose articles that do not define the Balance Bot’s character or use. Rather, they work in conjunction with other components (e.g., sensors, motors, H-bridge) to enable the operation of the good. Packaging the components of the Domino Robot 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 Domino Robot Hack Pack will be Taiwan, Italy, Malaysia, or Vietnam (the country of origin of the microcontroller) and China (the country of origin of the remaining components). 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