The country of origin of wired headsets

N354692 October 30, 2025 OT:RR:NC:N2:209 CATEGORY: Origin Aaron Marx Crowell & Moring, LLP 1001 Pennsylvania Ave Washington, DC 20004 RE: The country of origin of wired headsets Dear Mr. Marx: In your letter dated October 7, 2025, you requested a country of origin ruling on headphones on behalf of your client Sonova Consumer Hearing USA LLC. The item concerned is referred to as the HD 505 Series Headphones. The headphones are considered passive headphones, which does not contain any electronics related to amplification, active noise cancellation, or other components to process/alter the incoming analog audio signals. Additionally, it does not have wireless or Bluetooth capabilities and only connects to the audio source using a single audio cable. The headphones consist of a right and left transducer (speaker), housed within a padded ear cup, which are connected to each other with a headband assembly. We note that the headphones use the transducers to convert the analog audio signal into sound without any active electronic amplification, signal processing, or external power source. These headphones undergo a manufacturing process in both Ireland and China. Each headphone contains two (2) transducers/speakers. Transducers are the key components that convert electrical signals into audible sound waves. The transducer is the dominant component of these particular headphones. The transducers are manufactured in Ireland. The manufacturing process within Ireland consists of: Diaphragm Manufacture. Diaphragms are the vibrating part that produces sound. A diaphragm is manufactured using specific materials and techniques. The manufacturing process involves thin film deposition and forming with specialized machines. The production process has a high impact on the acoustic properties of transducer. Voice Coil Manufacture. Voice coils are the coil of wire attached to a speaker cone. It is the essential component in speakers, converting electrical signals into an electromagnetic moving force. Voice coils are custom designed and manufactured to meet specific application requirements, including wire size, shape, insulation, and winding configuration. Wire Formation. This process step focuses on the formation of the lead-in wires of the coil to a desired shape by terms of a specialized mechanical process. The goal of this forming is to shape the lead-in wires to a geometry whose strain relief increases its durability without deteriorating the diaphragm movement (e. g. rocking modes). Integration and Chassis Assembly. A chassis provides not only the positioning of the diaphragm-coil subassembly into the magnet gap but also provides the acoustic function. Thus, high mechanical accuracy of the assembly of the diaphragm-coil subassembly into the chassis is mandatory. Bonding. Bonding involves precisely soldering the wires to the contacting areas of the chassis. All of this must be precisely conducted to ensure electrical connectivity within the whole frequency spectrum of the electrical signal without losing the robustness of the joint. Acoustic Testing. Acoustic testing involves evaluating the performance across various proprietary measures such as frequency response, total harmonic distortion (“THD”), and other sound artifacts. Testing requires specialized tools, equipment, software, test routines, signal evaluation algorithms as well as specialized employees trained in subjective listening tests. The various mechanical/structural components (headband assembly, earcup housing, fasteners, padding, etc.) are manufactured within China. The transducers/speakers of Irish origin are imported into China and assembled with the various other components. In China, the finishing processes are assembly oriented. They do not require technical programming or alteration of the transducers. There is no significant software or hardware development, nor is any firmware altered during the assembly process. Manufacturing process within China: Soldering. A process of joining two or more metal pieces together by melting a filler metal (solder), to create a strong and electrically conductive bond between parts. Screwing. Physically attaching parts with a screw. Push fit. A method of joining fittings that require no soldering or gluing. Gluing. The process of joining parts together using an adhesive bond. 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Based on the information provided, it is the opinion of this office that the transducers/speakers manufactured in Ireland impart the character of the finished article and would be considered the dominant component of the finished good. The various components used in the manufacturing process are substantially transformed into a different article with a new name, character and use as a result of the processing that takes place in Ireland. The assembly process that takes place in China will not change the character and end use of the product that was already realized in Ireland. Therefore, since a substantial transformation does not occur as a result of the Chinese processing, the country of origin of the finished HD 505 Series Headphones, would be Ireland for marking purposes upon importation into the United States. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division