The country of origin of dog training devices

N353542 October 3, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Sara Zhang Shanghai Rocks International Co., Ltd Room 204, No 69, Husong Road 1399, Songjiang District Shanghai 26000 China RE: The country of origin of dog training devices Dear Ms. Zhang: In your letter dated September 10, 2025, you requested a country of origin ruling. There are three items at issue with this request. The first two items are both described as rechargeable remote dog trainers and individually identified by item numbers 1858654 and 1858655. The subject articles are packaged in a kit containing a training collar with polyester strap, remote control, charging cable, and other components such as wrist straps, metal prongs, and batteries. The training collars are designed to be worn by the dog, allowing the incorporated metal prongs to come in contact with the neck. The remote control is used by the owner to deliver a corrective notification in the form of a sound, vibration, or electric shock when any unwanted behavior is perceived. The primary difference between the two models is the working range that the remote and collar can function within. The third item is identified by part number 2374260 and described as a rechargeable smart dog bark collar. The device consists of the training module, which incorporates a microphone, speaker, and metal prongs, attached to a collar. The device is worn on the dog’s neck, and the microphone detects any barking sound. When the bark is detected, the module delivers the desired correction, including a sound, vibration, or electric shock. In your request, you state that the manufacturing process for all three items occurs in Vietnam. This process begins with the manufacture of the various printed circuit board assemblies (PCBAs) through surface mount technology (SMT). These PCBAs include the control center, communication, drive hardware, and power management for the training collar and remote control in the first two devices. For the bark collar, the PCBA incorporates the control center, bark detection, correction execution, and power management. Once the PCBAs are created, they are placed within their respective plastic enclosures, which incorporate the metal prongs, both of which originate from China. The enclosure incorporates an LCD screen, which is also sourced from China. The first two dog trainers are then tested for function and packaged with the rest of the components of the kit. We note that the remainder of these components are stated to be from China. The bark collar is tested and packaged for shipment to the United States. 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). Regarding the origin of the subject articles, it is the opinion of this office that the various PCBAs, which are manufactured in Vietnam, impart the character of the finished devices as they provide the essential electrical functionality. Further, the addition of any Chinese components does not effect a substantial transformation of these PCBAs into new and different articles of commerce. As such, the country of origin for the dog trainers, part numbers 1858654 and 1858655, and the bark collar, part number 2374260, will be Vietnam. 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division