The country of origin of an audio interface device

N356637 December 17, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Melissa Miller Proctor Miller Proctor Law PLLC 16427 N. Scottsdale Road, Suite 410 Scottsdale, AZ 85254 RE: The country of origin of an audio interface device Dear Ms. Miller Proctor: In your letter dated December 2, 2025, you requested a country of origin ruling on behalf of your client, Focusrite Group US, Inc. The merchandise under consideration is identified as the ISA C8X and is described as an input signal amplifier audio interface. The subject device is further described as an analog microphone preamplifier and signal converter for professional music recording and production. The interface is comprised of multiple printed circuit board assemblies (PCBAs) within an enclosure. The front of the device is equipped with various knobs, buttons, sliders, and LED displays, which function together as the user interface for the device. The back of the device incorporates various audio inputs and outputs for the connection of microphones, speakers, and other audio input devices. The subject device is designed to function as an interface between the user’s computer and various audio inputs for music production, processing, and mixing. The device converts the analog sound from the input into digital form, making it accessible to alter with the computer. The device can further convert the digital signal back to analog for audio output. In your request, you note that there are three primary PCBAs, which provide the necessary functions of the device. The Main PCBA contains the analog/digital conversion functions as well as the digital signal processing architecture. The Preamp PCBA contains the ISA preamp electronics as well as various microphone preamplifiers. The final PCBA is the Front Panel PCBA, which contains the LEDs as well as the control and user interface electronics. Based on the information provided, the Main PCBA functions as the essential component of the finished device. You propose three manufacturing scenarios for the interface device, upon which you would like this office to review. In scenario one, the Main PCBA is manufactured and programmed in Malaysia. The process includes the placement of the various electronic components, including the converter circuits and digital signal processor, on the board via surface mount technology (SMT). The finished PCBA is then sent to China where the Preamp PCBA and Front Panel PCBA are manufactured via SMT procedures. The three PCBAs are then assembled within the enclosure before the finished device is tested, inspected, and packaged for shipment to the United States. The second scenario begins with both the Main PCBA and Preamp PCBA being manufactured, via the same SMT operation described above, in Malaysia. The two PCBAs are then sent to China where they are combined with the Front Panel PCBA, which in this case is manufactured in China, and installed within the enclosure. The finished device is then tested, inspected, and packaged for shipment to the United States. The final scenario begins with all three PCBAs (Main, Preamp, and Front Panel) being manufactured via SMT processes in Malaysia. All three PCBAs are then sent to China where they are assembled within the final enclosure. The finished device is then tested, inspected, and packaged for shipment to the United States. 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). Regarding the origin of the subject interface device, it is the opinion of this office that the Main PCBA, as it contains the digital signal processing and conversion functions, imparts the character of the finished device. In all three scenarios, this PCBA is fully manufactured in Malaysia. In scenario one, the addition of the Preamp and Front Panel PCBAs as well as the minimal operations performed in China would not substantially transform the main PCBA into a new and different article of commerce. In scenarios two and three, the production of the Preamp and Front Panel PCBAs in Malaysia further enhance the functions that are added from the processes performed in that country. Accordingly, the country of origin for the ISA C8X as presented in all three scenarios, will be Malaysia. 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division