The country of origin of noise cancelling headphones

N351861 August 14, 2025 OT:RR:NC:N2:209 CATEGORY: Origin Jane Li 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 noise cancelling headphones Dear Ms. Li: In your letter dated July 31, 2025, you requested a country of origin ruling on noise cancelling headphones. The items concerned are Bluetooth enabled noise cancelling headphones, model # WX-607A. The research and development of the plastic parts/housing and the printed circuit board assembly (PCBA) are undertaken in China. The noise cancelling headphones are made 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: All plastic housing components are produced. All printed circuit boards are manufactured. All printed circuit boards are populated using surface mount technology. The components of the PCBAs are sourced mainly from the Philippines with only the integrated circuits, mems microphone, and USB-C connector being of Chinese origin. PCBA is tested. Plastic parts/housing are assembled. The wires and batteries are soldered to the PCBA (battery of Chinese origin). The PCBA is installed onto the ear shell. The speaker is soldered to the PCBA (speakers of Philippine origin). Battery EVA foam is attached. Ear cap is assembled. Various testing occurs. Headphones are packaged. 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 take place in the Philippines are both meaningful and complex, resulting in the creation of Bluetooth enabled noise cancelling headphones. The various components 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 Bluetooth enabled noise cancelling headphones 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