The country of origin of a self-cleaning cat litter box

N354665 November 3, 2025 OT:RR:NC:N4:410 CATEGORY: Origin Kim McDaniel Radio Systems Corporation DBA PetSafe Brands 10427 PetSafe Way Knoxville, TN 37932 RE: The country of origin of a self-cleaning cat litter box Dear Ms. McDaniel: In your letter dated September 30, 2025, you requested a country of origin ruling on a self-cleaning auto cat litter box for the purposes of applying the current trade remedies and marking. Pictures and product specifications were submitted with your request. The product under consideration is identified as SmartSpin Litter Box (the “litter box”). You described that the litter box is a self-cleaning device that connects to an app on smart phone. It has an optional deodorizer. The cleaning cycle starts once a cat leaves the litter box. The default countdown is 3 minutes and can be adjusted between 3-60 minutes (only in the app). The litter box uses an infrared motion detection sensor as well as a weight sensor. One set of detectors are responsible for detecting when the waste bin is full. Another set of detectors are situated along the side to implement an anti-pinch feature, enhancing safety for both the cat and the user. The litter box consists of plastic parts, printed circuit boards assemblies (PCBAs) and other electric/electronic components, e.g., electric motor(s), switches, sensors, etc. The plastic parts include an inside back half, an inside front half, an outer side storage plate, an inside soft pad, a bottom base, an outer side sieve plate, an outer side cover, an inside side cover, a waste collection box, four feet, and the cleaning mechanism (comprised of motorized rake sweeper, rotating drum, sifting system). There are six PCBAs incorporated in the litter box. One is the main PCBA, which controls all subsystems and processes data received from the other six PCBAs. The main PCBA contains the memory data required to operate the litter box, fulfilling all functions which include control turning the ball, weighting, connecting to WI-FI, APP control, and providing the signals for operation of the display panel to show machine states. The second PCBA receives signals from the main board to control LEDs on it to show machine status (equipped with two buttons, one for Wi-Fi connecting, and the other is to clean cat litter). The third and fourth PCBAs are responsible for HALL sensor’s function, i.e., the third one detects whether the machine cover is in position and the fourth one is to detect the position of the ball. The fifth and sixth PCBAs are used to detect whether the cat gets in the wrong place and if the waste bin is full. The manufacturing process of the litter box starts with the fabrication of the PCBAs in Vietnam, in which various discrete electronic components, such as resistors, capacitors, transformers, diodes, triodes, and integrated circuits, etc., are attached to the bare PCBs via SMT (Surface Mount Technology) placement, DIP (Dual In-line Package) insertion, welding, testing, three-proof coating and finished product assembly. Also in Vietnam, the PCBAs are loaded with firmware and tested. The deodorizer is made from essential oil products from Canada and China. The Vietnamese originating PCBAs will be shipped to China, where they will be incorporated into the Chinese originating components and parts (the plastic parts, and the electric/electronic components) to make the finished litter box. The final assembly is 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Based on the information submitted, an overwhelming majority of the components or parts are made in China, where the Vietnamese-origin PCBAs (and/or the optional deodorizer) are combined with Chinese-origin components or parts and manufactured into different subassemblies, which are ultimately assembled into the subject finished litter box. It is of our view that the manufacturing processing performed in China results in a substantial transformation, such that the Vietnamese-origin or the other non-Chinese origin materials lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. Therefore, the country of origin for the litter box is China for purposes of applying the current trade remedies and country of origin marking. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division