The country of origin of an audio amplifier/speaker

N354778 October 24, 2025 OT:RR:NC:N2:209 CATEGORY: Origin William Maloney Sandler, Travis & Rosenberg, P.A. 286 Madison Avenue, Suite 502 New York, NY 10017 RE: The country of origin of an audio amplifier/speaker Dear Mr. Maloney: In your letter dated October 8, 2025, you requested a country of origin ruling on an audio amplifier/speaker assembly, on behalf of your client, Guitar Center, Inc. The item concerned is referred to as the Harbinger VARI V1112 audio amplifier/speaker. The subject amplifier/speaker is a portable sound system with advanced electronic features for amplification and sound reproduction of instruments and voice. It includes a pre-amp and sound mixer with multiple inputs to support instruments and microphones. The Harbinger VARI V1112 audio amplifier/speaker incorporates components from various countries including Thailand and China. It will undergo manufacturing/processing in Thailand and China before being imported into the United States from China. The back panel (chassis assembly), which houses the electronics needed to provide the amplification and other functionality, is manufactured within Thailand. The chassis incorporates various printed circuit board assemblies (PCBAs), knobs, and wire/cables. PCBAs manufactured in Thailand: Pre-Amp PCBA Power-amp PCBA Power supply PCBA Bluetooth PCBA LED PCBA The PCBAs and panels (chassis) are manufactured in Thailand. These are then sent to China where they are assembled with Chinese origin speakers into a Chinese origin enclosure. 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 upon the facts presented, it is the opinion of this office that the character of the finished audio amplifier/speaker is imparted by the back panel chassis assembly, which would be considered the dominant component. The back panel chassis assembly is manufactured within Thailand from various PCBAs which are also manufactured within Thailand. The subsequent manufacturing/assembly steps undertaken in China do not affect a substantial transformation. The back panel chassis assembly retains its own identity with a predetermined end use. Therefore, since a substantial transformation does not occur as a result of the Chinese processing, the country of origin of the finished Harbinger VARI V1112 audio amplifier/speaker will be Thailand for origin and marking purposes at time of 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