The country of origin of analog multimeters and a battery tester

N351913 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 analog multimeters and a battery 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 analog multimeters and a battery tester. Descriptive literature was provided for our review. The first items under consideration are described as analog multimeters (model numbers GMT-312, GMT-318, and GMT-319), which are electronic instruments that measure AC/DC voltage, current, and resistance. To operate, the user selects the desired measurement function (voltage, current, resistance, etc.) using the rotary dial on the multimeter. The black probe is plugged into the common terminal and the red probe is connected to the appropriate terminal depending on the measurement function selected. For example, to measure the voltage, the multimeter is connected in parallel with the component or circuit being tested and then measures the potential difference between two points. The user then observes the needle’s position on the appropriate scale to obtain the measurement. The primary differences between the GMT-312, GMT-318, and GMT-319 lie in their measurement ranges, internal circuitry designs, and material compositions. The second item under consideration is described as a battery tester (model number GBT-500A), which is an electronic device designed for assessing the charge level of dry-cell batteries and measuring the battery voltage. It can test a wide range of batteries, from 1.5V button cells to 22.5V photo and lantern cells. The tester features an easy-to-read, color-coded “Good/Replace” indicator and includes test leads for comprehensive testing. Its principal components include a printed circuit board assembly (PCBA), dial scale, pointer magnetic core, built-in test probe, rotary selector switch, input/output battery clamp or terminal, and the molded plastic housings. The manufacturing and assembly process for both the analog multimeters and battery tester occurs in Vietnam and is a substantially similar process. It starts with the assembly and inspection of the analog meter dial head by adding the dial scale, pointer magnetic core, and dust covers produced in China. These are combined with the plastic housings, lenses and zero adjusters manufactured in Vietnam and is followed by a quality inspection. Next, the PCBA is created 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 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. Finally, the completed PCBA is installed into the analog meter dial head along with other components such as the knob, metal parts, bottom housing, and built-in test probe. The finished articles are then sent to China for 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 analog multimeters (model numbers GMT-312, GMT-318, and GMT-319) and the battery tester (model number GBT-500A), 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 analog multimeters (model numbers GMT-312, GMT-318, and GMT-319) and the battery tester (model number GBT-500A) 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