The country of origin of wired earbuds

N355696 November 24, 2025 OT:RR:NC:N2:209 CATEGORY: Origin Allen Lei Vietnam Topway EM Technology Limited Company Cap Nhat Village, Tien Tien Commune Hai Duong City T016483059 Vietnam RE: The country of origin of wired earbuds Dear Mr. Lei: In your letter dated November 4, 2025, you requested a country of origin ruling on wired earbuds on behalf of your client, Sakar International, Inc. The item concerned is referred to as the Infinitive Noise Isolating Earbuds, SKU 751965. These are wired earbuds that incorporate two earbuds/speakers at one end of a length of cable and an audio plug at the opposite end. The cable is manufactured in a “Y” configuration which allows the correct stereo signal to be delivered to each of the users ears. These particular ear buds are black in color. The majority of the components are manufactured in China: speakers audio plug speaker housing silicone caps polyurethane enameled wire (raw cable material) PVC material (raw cable material) The Chinese components/materials are sent to Vietnam, where they are manufactured into the finished earbud assemblies. Within Vietnam the electrical audio cable is manufactured from the raw enameled wire, PVC material and an audio plug. The raw enameled wire is cut to length and covered with a PVC jacketing. Then the jacketed wires are arranged into their final ”Y” shaped configuration and covered with an outer cable jacketing. The audio plug is soldered to the cable assembly and then over molded to create a finished audio plug assembly. At the inter-section of the “Y” or the Y-split is reinforced with additional molded piece to give strength to the cable and enhance durability. After the cable assembly is completed, the cable is tested. Next the cable assembly is manufactured into the finish commodity by assembling it with the remaining components. The spearers are soldered on to the cable, then their housings and silicon earbud pads are added. The final assembly is then tested again. A complete explanation of the manufacturing process has been submitted. 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). Based upon the facts presented, it is the opinion of this office that the character of the finished wired earbuds is imparted by the Chinese origin speakers, which would be considered the dominant component. The subsequent manufacturing/assembly steps undertaken in Vietnam do not affect a substantial transformation. Within Vietnam, the speakers, earbud housings and silicon caps (all of which are of Chinese origin) are assembled together and then soldered to a Vietnamese origin cable assembly. This simple assembly process is not complex and does not alter the predetermined end use of the speakers. As such, the country of origin of the finished Infinitive Noise Isolating Earbuds, SKU 751965 will be 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division