The country of origin of a gaming controller

N355069 November 6, 2025 OT:RR:NC:N3:356 CATEGORY: Origin Joe Castillo Razer (Asia-Pacific) Pte. Ltd. 1 One-North Crescent #02-01 Singapore 138538 Singapore RE: The country of origin of a gaming controller Dear Mr. Castillo: In your letter dated October 21, 2025, you requested a country of origin ruling. The good under consideration is the Razer Wolverine V3 Tournament Edition 8K PC gaming controller, Model RZ06-05550100-R3U1. It is a wired gaming controller that is compatible with a personal computer only. According to the information provided, the subject controller contains a printed circuit board assembly (PCBA) that is manufactured in Vietnam via a surface mount technology (SMT) process, utilizing components sourced from various countries. The SMT process includes adhering integrated circuit chips, transistors, resistors, capacitors, etc., to a bare printed circuit board (PCB). The functional PCBA will be exported from Vietnam to China for final assembly. The final assembly in China consists of placing the PCBA in a plastic casing and attaching other parts, including brackets, buttons, a directional pad, thumbsticks, connectors, grips, a battery, etc. The completed game controllers are inspected, tested, labeled, and packaged 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 PCBA contributes to the main functionality of the finished merchandise. The complex SMT manufacturing process, which includes the placement of numerous individual components onto a bare PCB, results in a substantial transformation of the components to produce a functional PCBA of Vietnamese origin. Additionally, the assembly process performed in China does not substantially transform the PCBA of Vietnamese origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, we find that the country of origin of the Razer Wolverine V3 Tournament Edition 8K PC gaming controller, Model RZ06-05550100-R3U1, is 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 Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division