The country of origin of in-dash car stereos

N353105 September 23, 2025 OT:RR:NC:N2:208 CATEGORY: Origin Kayla Owens Stein Shostak Shostak Pollack & O'Hara 445 S. Figueroa Street, Suite 2388 Los Angeles, CA 90071 RE: The country of origin of in-dash car stereos Dear Ms. Owens: In your letter dated August 29, 2025, on behalf of AVA Enterprises Inc., you requested a country of origin ruling determination for in-dash car stereos. The merchandise under consideration consists of in-dash car stereos, model numbers BE10ACP.X V:2L, BE7ACP.X V:2L, and BCPA8 V:8L, which are aftermarket products installed in vehicles by their owners. These in-dash units include LCD touchscreen displays, Bluetooth capabilities, Apple CarPlay, Android Auto, SiriusXM-Ready, and AM/FM radio receivers. They do not contain CD/DVD players. The manufacturing process for all of the subject in-dash units will be the same. In Malaysia, the motherboard and amplifier board are manufactured using surface mount technology (SMT). This process includes the following steps: PCB loading operation, press, solder paste inspection operation, high-speed SMT operation, automated optical inspection (AOI), pan speed SMT operation, reflow soldering operation, (AOI) after furnace and manual board collection. After the SMT operations are completed, the finished motherboards and amplifier boards will be sent to China for assembly and packaging. In China, the thin-film transistor (TFT) board and button board will be manufactured. In addition, the final assembly is done in China, which includes pre-processing the wires, brackets, covers, and panels, as well as assembling the motherboard, heat sink, back cover, front cover, keyboard, knobs, TFT bracket, LCD screen, TFT board, MIC board, and back cover. Testing, inspection, and packaging with bundled accessory components are also performed in China. 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 on the information provided, it is the opinion of this office that the motherboards and amplifier boards contribute to the main functionality of the finished merchandise. The complex SMT manufacturing production of these boards, which includes the placement of numerous individual components onto a bare PCB, creates functional Printed Circuit Board Assemblies (PCBAs) that result in a substantial transformation of the components to produce motherboards and amplifier boards of Malaysian origin. Additionally, the assembly process performed in China would not substantially transform the motherboards and amplifier boards of Malaysian origin into a new and different article of commerce with a name, character, and use distinct from that of the exported goods. Accordingly, we find that the country of origin for the in-dash car stereos, model numbers BE10ACP.X V:2L, BE7ACP.X V:2L, and BCPA8 V:8L, is Malaysia. 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 Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division