The country of origin of a digital compass

N357005 January 13, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Tei Zouen Kernel Hardware Engineering, Inc. 2-51 Oaki-Cho Nakamura-ku Nagoya 4530042 Japan RE: The country of origin of a digital compass Dear Mr. Zouen: In your letter dated December 15, 2025, you requested a country of origin ruling on a digital compass. Descriptive literature was provided for our review. The item under consideration is described as the Pole Finder NS-10 mkII, which is a compact, digital electronic compass designed to assist in the polar alignment of portable equatorial mounts for astrophotography. It is particularly useful for setting up a telescope or camera mount’s polar axis when the North Star (Polaris) is not visible. The Pole Finder NS-10 mkII operates by using a built-in 9-axis sensor (accelerometer, gyroscope, magnetometer) to sense the mount’s tilt and direction. It then displays the correct alignment position for Polaris (or the Southern Celestial Pole) on its LCD screen after input of the location’s latitude and magnetic declination, guiding the user to center the pole with on-screen graphics. The device measures 54mm by 54mm by 15mm and weighs 35g. The Pole Finder NS-10 mkII consists of items from both China and Japan. The Chinese-origin products consist of the M5Stack Core, which is the complete hardware for the finished unit, and the plastic case. The Japanese-origin items include the fixed plate, labels, instruction manual card, and NS-10 control software. You state in your letter that the M5Stack Core is a commercially available item constructed in China. You further state the core of your article is the Japanese software that provides the essential polar-alignment functionality and represents the primary source of the product’s overall value. The manufacturing process begins in Japan with the development of the proprietary software. This starts with the development of the initial screen display function including the level adjustment, latitude setting, polar alignment angle setting, calibration function, development of the polar alignment function and development of other auxiliary functions as required. The next step is the installation of the software onto the main unit followed by functional inspections of each component, including verification that all functions operate according to specifications. Then, the final product is labeled, fully charged, and packaged for sale. When determining the country of origin, 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). In regard to the country of origin of the Pole Finder NS-10 mkII, it is our opinion the Chinese M5Stack Core is not transformed into a new article with a name, character, and use different than when imported into Japan. While the Japanese software enhances the usability of the product, it still has all of the necessary sensors and hardware to perform many of the essential operations. Therefore, in our opinion, the country of origin of the Pole Finder NS-10 mkII is China, which is where the majority of the hardware components are manufactured. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division