The country of origin of wired earbuds

N350937 July 24, 2025 OT:RR:NC:N2:209 CATEGORY: Origin Jane Lee D and S Industries (Philippines) Corporation Unit 1-5 of Orient Goldcrest Suntrust Ecotown Building 2, Cavite 4108 Philippines RE: The country of origin of wired earbuds Dear Ms. Lee: In your letter dated July 3, 2025, you requested a country of origin ruling on wired earbuds. The items concerned are USB-C wired earbuds, model # ES630A-1. The research and development of the wired earbuds is undertaken in China. The wired earbuds are manufactured from components sourced from the Philippines and China. The actual manufacturing/assembly steps are undertaken in the Philippines. The manufacturing steps that take place in the Philippines include in part: Populate both (2) printed circuit boards using surface mount technology. The components of the PCBAs are sourced mainly from the Philippines with only the USB-C connector and an integrated circuit chip of Chinese origin Produce the insulated wire Assemble the wire assembly (i.e. cut length, solder on connectors, connect the left and right channel cords, injection molding of various connectors and joints, etc.) Manufacture all plastic housing components Assemble PCBA and microphone on wire assembly/volume controller (microphone sourced from China) Solder speakers to wire assembly within earbud housings (speakers sourced from China) Assemble the upper and lower plastic covers Testing/inspection and packaging 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 upon the facts presented, it is the opinion of this office that the manufacturing processes that takes place in the Philippines are both meaningful and complex, resulting in the creation of USB-C wired earbuds. The various components (i.e. speakers, microphone, type c connector, and an integrated circuit chip) used in the manufacturing process are substantially transformed into a different article with a new name, character, and use as a result of the processing that takes place within the Philippines. Therefore, the country of origin of the finished USB-C wired earbuds will be the Philippines. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division