The country of origin of digital multimeters and a receptacle tester

N351911 August 20, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Chuhao Lan Yingke Law Firm 39F, 501, Yincheng Middle Road, Pudong New District Shanghai 20012 China RE: The country of origin of digital multimeters and a receptacle tester Dear Ms. Lan: In your letter dated August 1, 2025, on behalf of your client, Shanghai SDAR Electronic Instruments, Co., Ltd., you requested a country of origin ruling on digital multimeters and a receptacle tester. Descriptive literature was provided for our review. The first items under consideration are described as digital multimeters (model numbers GDT-311, GDT-3190, GDT-3200, and 42095RAW), which are electronic instruments that measure AC/DC voltage, current, and resistance. The devices operate by using a combination of analog and digital circuitry to convert the electrical signal into a digital reading displayed on the LCD screen. The user selects the appropriate function (voltage, resistance, or continuity) and range using the rotary dial, then connects the test leads to the circuit or component being measured. The main difference between the GDT-311 and GDT-3190 lies in the measurement range. The GDT-3200 can also measure diodes and temperature and is equipped with a buzzer function. Compared with other models, the 42095RAW digital clamp multimeter is additionally equipped with a clamp jaw for measuring high currents. The second item under consideration is described as a ground fault circuit interrupter (GFCI) receptacle tester (model number HGT6520), which is an electronic instrument used to check whether the wiring of a GFCI outlet is correctly installed. It works by plugging the device into an outlet and using a single LED indicator to display various wiring conditions, including correct wiring, open ground, open neutral, hot/ground reverse, and hot/neutral reverse. Additionally, it can be used to test the functionality of the GFCI by pressing a dedicated test button, which should trip the GFCI if it is working correctly. Its main components include a printed circuit board assembly (PCBA), light emitting diode (LED) indicators, a metal plug, button, and plastic housings. The manufacturing and assembly process for both the digital multimeters and GFCI receptacle tester occurs in Vietnam and is a substantially similar process. It starts with the PCBA creation using surface mount technology (SMT) in Vietnam. The electronic components (resistors, capacitors, etc.) from various countries are mounted onto the printed circuit board (PCB). This involves a solder paste application, placement of components, reflow soldering, cleaning, and testing to ensure circuit functionality. The next process includes the chip-on-board (COB) processing where the PCB is cleaned, glue is dispensed, and the semiconductor die is unpackaged and attached to the PCB. Additional steps include wire-bonding, functionality testing and epoxy encapsulation. This portion of the process is only applicable to the manufacturing of digital multimeters and does not apply to the HGT6520 GFCI Receptacle Tester. The next process for both the multimeters and the receptacle tester also occurs in Vietnam and includes the through-hole assembly and testing where the remaining larger components (from various countries including China) are manually inserted and soldered onto the PCB. For the digital clamp multimeter (42095RAW), the PCBA assembly process and final inspections will be completed in Vietnam. For the remaining items, the final assembly and inspection occurs in China. The completed PCBA is installed into the Chinese-origin plastic housings, along with other components manufactured in China such as the LCD displays and LED indicators, selector knobs, metal plug and connectors. The entire final assembly process predominately involves the integration of the pre-manufactured functional components from Vietnam into the product housings. The last step includes the final packaging and labeling. When determining the country of origin, 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). Regarding the country of origin of the digital multimeters (model numbers GDT-311, GDT-3190, GDT-3200, and 42095RAW) and the GFCI receptacle tester (model number HGT6520), it is our opinion that the assembly process performed in Vietnam is considered complex and results in a substantial transformation of over a hundred different components. Most importantly, the creation of the PCBA in Vietnam using SMT generates a working measuring device. This PCBA creation and additional assembly in Vietnam creates a new and different article of commerce with a name, character, and use distinct from the individual Chinese and foreign components. Accordingly, the country of origin of the digital multimeters (model numbers GDT-311, GDT-3190, GDT-3200, and 42095RAW) and the GFCI receptacle tester (model number HGT6520) will be Vietnam, which is where the PCBA creation, programming and assembly occurs. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division