The country of origin of a gaming controller

N355986 December 10, 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 November 13, 2025, you requested a country of origin ruling. The good under consideration is the Razer Kitsune All-Button Arcade Controller. It is a wired gaming controller that is compatible with both the Playstation 5 and a personal computer. Your submission includes three styles of this controller (Razer Kitsune, Model RZ06-05020100; Razer Kitsune Esports Green, Model RZ06-05020500; and Razer Kitsune 2XKO, Model RZ06-05020600), which differ only in the surface color and/or design of the casing. According to the information provided, the subject controller contains a printed circuit board assembly (PCBA) that is manufactured in Thailand 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 Thailand 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, connectors, a top plate, 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 has occurred 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 Thai origin. Additionally, the assembly process performed in China does not substantially transform the PCBA of Thai 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 gaming controller is 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 Maryalice Nowak at maryalice.nowak@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division