The country of origin of gaming controllers

N350654 July 18, 2025 OT:RR:NC:N2:208 CATEGORY: Origin Joe Castillo Razer (Asia-Pacific) Pte. Ltd. 1 One-North Crescent #02-01 Singapore 138538 RE: The country of origin of gaming controllers Dear Mr. Castillo: In your letter dated June 26, 2025, you requested a country of origin ruling on Razer Wolverine gaming controllers. The merchandise under consideration is the Razer Wolverine V3 Pro Xbox Wireless Gaming Controller and the Razer Wolverine V3 Tournament Edition Xbox Wired Gaming Controller. Model numbers RZ06-05200100-R3U1, RZ06-05200200-R3U1, and RZ06-05200300-R3U1 are wireless controllers where each model number represents a different color (black, white, and esports green, respectively). Model numbers RZ06-05210100-R3U1 and RZ06-05210200-R3U1 are wired controllers where each model number represents a different color (black and white, respectively). The manufacturing process for both the wireless and wired controllers is the same. According to the information provided, both the wired and wireless modes of the controllers contain a printed circuit board assembly (PCBA) that is manufactured in Vietnam via surface mount technology (SMT) process utilizing components which are sourced from various countries. The SMT process includes adhering integrated circuit chips, transistors, resistors, capacitors, etc., to a bare printed circuit board (PCB). The functional PCBA will be sent from Vietnam to China for final assembly. The final assembly in China consists of the following: placing the PCBA in a plastic casing and screwing and pasting other parts, such as brackets, buttons, directional pad, thumbsticks, connectors, grips, batter, etc. The completed game controllers are inspected, tested, labeled, and packaged in China. When determining the country of origin for purposes of applying current trade remedies under Section 301 and 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). Based on the information provided, it is the opinion of this office that the PCBA contributes to the main functionality of the finished merchandise. The complex SMT manufacturing production of these PCBAs, which includes the placement of numerous individual components onto a bare PCB, creates functional PCBAs that results in a substantial transformation of the components to produce PCBAs of Vietnamese origin. Additionally, the assembly process performed in China would not substantially transform the PCBA of Vietnamese origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, we find that the country of origin for the Razer Wolverine V3 Pro Xbox Wireless Gaming Controller (models RZ06-05200100-R3U1, RZ06-05200200-R3U1, and RZ06-05200300-R3U1) and the Razer Wolverine V3 Tournament Edition Xbox Wired Gaming Controller (models RZ06-05210100-R3U1 and RZ06-05210200-R3U1) to be Vietnam. 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 Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division