The country of origin of a pool cleaning robot

N355237 November 19, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Sylvia Chen Shenzhen Ousike Trade Co., Ltd. 58/2000 No. 666, Building 3, Zaojin Industrial Park Songbai Road, Langxin Community Shiyang Sub-district Bao’an District, Shenzhen City China RE: The country of origin of a pool cleaning robot Dear Ms. Chen: In your letter dated October 24, 2025, you requested a country of origin ruling on a pool cleaning robot. Descriptive literature was provided for our review. The item under consideration is described as the iGarden K60 cordless, smart robotic pool cleaner designed for both floors and walls up to the waterline. It features a powerful engine with brushless motors, two rubber brushes, a large 4-liter filter basket, and a 6-hour runtime. The device has artificial intelligence (AI) navigation with an S-shaped path planning for up to 95% coverage, remote control via app, and automatic parking. Debris is collected using the onboard canister. The device contains parts from both Thailand and China. The Thai parts include the control board, impeller, chassis, charging fixing plate, and motor. The Chinese components include the foam, socket cover, screws, battery, O-ring, nylon, front and rear covers, charging wire cover plate, nuts, water sensor, shave strip, gear, brackets, side and decorative covers, drain cover, decorative covers, basket covers, tail pillar, bearings, seal ring, isolation column, motor bracket, power supply knob, snap buttons, various additional brackets, the IMU board, interaction board, adapter board, driving board, motor fixing plate, oil seal, rollers, shaft, magnet, gaskets, wheel hub, and the machine body and handle shell. The manufacturing includes a total of four steps. The first step includes the manufacture of the various subassemblies, which occurs in China. This includes screwing and gluing the motor subassembly, water pump motor subassembly, control box subassembly, charging cable subassembly, charging plug subassembly, and the battery subassembly together. The processing is then transferred to Thailand where the main printed circuit board assemblies (PCBA) are created using surface mount technology. The main control board includes a microcontroller (MCU), which is the core component that acts as the “central brain” of the robot vacuum. This is responsible for running pre-set programs and processing all data signals. The WiFi module enables device networking and remote communication, capable of receiving cloud commands or transmitting data with external devices (such as mobile phones or computers). It supports remote control and data synchronization. The power management module is responsible for distributing and stabilizing the power supply to the entire unit. It converts battery or external power into appropriate voltages for various components (e.g., 3.3V/5V for the MCU and sensors). It also includes overvoltage and overcurrent protection to ensure safe system operation. Finally, the sensor analog-to-digital signal processing module receives analog signals from external sensors (such as distance sensors, temperature sensors) and converts them into digital signals recognizable by the MCU, providing environmental data support for decision-making. The second board is the driver board, which acts as a “bridge” between the MCU and the actuators, its core function is to convert the low-power control signals output by the main control board into high-power drive signals. It precisely controls the start/stop, speed, and direction of the drive motors (for forward, backward, turning, and other movement actions) and the water pump motor. It employs techniques like Pulse Width Modulation (PWM) to achieve stepless speed regulation for the motors. The wiring board performs concentration and transfer functions. It centrally connects the wiring of all components, including the main control board, driver board, IMU board, HMI board, external sensors, and battery. This simplifies the wiring structure and reduces signal interference. It facilitates branched power transmission and aggregated signal distribution, ensuring efficient data and power flow between modules. It also streamlines future maintenance and troubleshooting. The Inertial Measurement Unit (IMU) acts as the robot’s balance and motion sensor. It houses a built-in three-axis gyroscope and a three-axis accelerometer. These components work together to continuously measure the robot’s angular velocity (e.g., speed of turning, tilting) and linear acceleration (e.g., force of accelerating, decelerating) in three-dimensional space. This data is transmitted in real-time to the main control board. The MCU then uses algorithms to interpret the robot’s current posture (e.g., tilt angle, direction of travel) and motion state, subsequently adjusting the motor control commands sent to the driver board. The infrared subassembly and water outlet cable subassembly are then constructed in step two in Thailand, which is where the finished good assembly is performed, additional functional tests, and finally, packing. 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 upon the facts presented, it is the opinion of this office that the manufacturing process of the iGarden K60 pool cleaning robot in Thailand, including the creation of the PCBAs and chassis, provides the essence of the pool cleaning robot. The item can only be used as a vacuum when it leaves Thailand. While some of the subassemblies are created prior to the final assembly, those subassemblies are more generic versions and cannot function without the instructions from the PCBAs. Accordingly, the origin of the iGarden K60 pool cleaning robot will be Thailand. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division