The tariff classification and country of origin of a drone set

N352538 October 3, 2025 CLA-2-95:OT:RR:NC:N3:356 CATEGORY: Classification; Origin TARIFF NO.: 9503.00.090; 9903.01.24; 9903.01.25 Jun Hee Choi Passwin Customs Service, Inc. 11, Beobwon-ro 11-gil, Songpa-gu Seoul 05836 Korea, South RE: The tariff classification and country of origin of a drone set Dear Mr. Choi: In your letter dated August 18, 2025, on behalf of your client, ALUX Co., Ltd., you requested a tariff classification and country of origin determination ruling. A description, photographs, and additional documentation regarding the CoDrone EDU (JROTC edition) (“CoDrone EDU-J”) were submitted with your inquiry. FACTS: The item under consideration is a drone set comprised of a drone, a wireless controller, a battery, and a battery charger. A product manual is also included. The drone measures 138.8 mm x 138.5 mm x 34.8 mm and weighs 54.8 grams. The battery requires 60 minutes to fully charge, which enables approximately 7 to 8 minutes of flight time. The drone’s maximum flight speed is 2.5 meters per second. You state that the CoDrone EDU-J is designed and intended for use in both educational and recreational settings. Specifically, it will be used in classrooms at the middle and high school levels to assist in Science, Technology, Engineering, Arts, and Mathematics (STEAM) instruction. Students will also use the drones to participate in annual competitions. Additionally, the item will be offered for sale directly to individual consumers for recreational use. It is recommended for ages 12 and older. The manufacturing operations are as follows: A driving motor and a vibration motor, to be installed into the drone and the controller, respectively, are sourced from China. Additional components, including capacitors, inductors, resistors, transistors, sensors, connectors, batteries, chargers, and plastic cases, are sourced from various countries in Asia, including China, Vietnam, Japan, and Malaysia. All these components are exported to South Korea. In South Korea: Bare printed circuit boards (PCBs) are procured from a domestic supplier. Electronic components are mounted onto the PCBs using Surface Mount Technology (SMT). The completed PCB assemblies (PCBAs) are assembled, together with additional parts, into the drone and controller cases. The driving motor is assembled into the drone, and the vibration motor is assembled into the controller. Software to enable flight, direction control, and coding capabilities is developed and installed onto the finished good. The drone and controller are assembled into a retail box, along with a battery charger, batteries, a cable, and additional parts such as extra propellers. The completed drone sets are exported to the United States. CLASSIFICATION: You suggest classification of the CoDrone EDU-J in subheading 9503.00.0090, Harmonized Tariff Schedule of the United States (HTSUS). We agree. As noted above, the CoDrone EDU is a set comprised of a drone, a wireless controller, a battery, batteries, a cable, and additional components. It is classifiable as a set pursuant to General Rule of Interpretation 3(b), HTSUS, with the essential character imparted by the drone. The applicable subheading for the CoDrone EDU-J will be 9503.00.0090, HTSUS, which provides for “Tricycles, scooters, pedal cars and similar wheeled toys… dolls, other toys… puzzles of all kinds; parts and accessories thereof… Other.” The column one, general rate of duty will be Free. COUNTRY OF ORIGIN – LAW AND ANALYSIS: When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). You suggest that the software developed in South Korea, which enables the drone’s core functions such as ascending, descending, and changing directions, results in a substantial transformation of the good’s foreign components. We disagree. It is our position that the driving motor installed in the drone, which is the component that enables the drone to fly, imparts the essential character to the finished good. Accordingly, we find that the country of origin of the CoDrone EDU-J, as produced in the manner described above, is China. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition to subheading 9503.00.0090, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e., 9903.01.25, in addition to subheading 9503.00.90, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. 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 Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division