The country of origin of NextVein Projection Vein Finder

N355289 November 17, 2025 OT:RR:NC:N3:135 CATEGORY: Origin Ron Goldman NextVein LLC 2 Union Place Huntington, NY 11747 RE: The country of origin of NextVein Projection Vein Finder Dear Mr. Goldman: In your letter dated October 27, 2025, you requested a country of origin ruling on the NextVein Projection Vein Finder. The NextVein Projection Vein Finder (Product Model: V800NV) is a hand-held, vein scanning and projection device that assists trained medical personnel to locate a suitable position for venipuncture and other medical procedures requiring the location of superficial veins. It comprises the following components: a main Printed Circuit Board Assembly (PCBA) module, a button plate PCBA, an optical module, front and rear plastic shell modules (housing), a stainless-steel protective cover, a button silicone film, a window silicone film, a lithium-ion battery pack, screws, studs, quartz glass, and labels. Each device is packaged with a power adapter, an adapter power cord, a user manual, and packaging materials. All these components are sourced from China. In Singapore, the manufacturing process involves several stages. Initially, the main module and button plate PCBA are integrated into the optical module using pressing, screwing, inserting, and plugging techniques, with connector wires secured by glue. This optical module assembly then undergoes a debugging test, which includes manual alignment of all projection parameters to ensure precision. Following this, the final assembly takes place, involving screwing, plugging, gluing, and snapping as the rear plastic shell is assembled with the optical module, and then the front plastic shell and battery are installed. Once the complete machine assembly is finished, the device proceeds through the following steps: a pre-production self-inspection, 24-hour room temperature aging, a post-production self-inspection, a safety test, a functional test, label printing, cleaning, packing, quality control, and final packaging for shipment. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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). In this case, the NextVein Projection Vein Finder, assembled in Singapore from entirely Chinese components, does not undergo a substantial transformation during its manufacturing process. The assembly operations, which employ pressing, screwing, inserting, gluing, snapping, and plugging techniques with tools such as an electric screwdriver, air duster blower, and UV-light lamp, do not constitute a complex or meaningful operation. Furthermore, the debugging phase does not substantially transform the optical module assembly into a new product. Similarly, the subsequent testing, inspection, cleaning, label printing, quality control, and packaging operations are considered minor finishing operations that do not result in a substantial transformation. Consequently, as the Chinese components are not substantially transformed, the country of origin for the NextVein Projection Vein Finder is China. 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 Fei Chen at fei.chen@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division