The country of origin of a radio frequency identification (RFID) silicon bracelet

N357333 January 21, 2026 OT:RR:NC:N2:208 CATEGORY: Origin Francesco Cantagallo Novemm srl Via Circonvallazione Alberto Lolli Ghetti n.25 Ferentino 03013 Italy RE: The country of origin of a radio frequency identification (RFID) silicon bracelet Dear Mr. Cantagallo: In your letter dated December 26, 2025, you requested a country of origin. The merchandise under consideration is a Radio Frequency Identification (RFID) silicon bracelet that is used as a Tesla Key to lock, unlock, and start a Tesla vehicle, which is referred to as a "Tesla Key Bracelet." This RFID silicon bracelet contains an RFID module, an NFC antenna, and a secure microcontroller. Moreover, the imported RFID bracelet, which is imported recorded with a code, stores and transmits data. The production processes for the subject RFID silicon bracelet are performed in different countries. The SmartMX3 P71 secure microcontroller is manufactured in the Netherlands using a specialized semiconductor process focused on high security and performance. This process includes wafer fabrication, which begins with CMOS040 technology on 90nm German wafers. It is the opinion of this office that the SmartMX3 P71 secure microcontroller is the main functional component ("brain") that transmits, controls, and stores the data and contains the memory integrated circuit. As per the information provided, the printed circuit board assembly (PCBA) is assembled in the United States. This process entails assembling together the PCB, RFID antenna, and the secure microcontroller. In addition, the firmware is put onto the microcontroller in the United States. The printed circuit board assembly provides a mounting and interconnection, integrating the microcontroller and the antenna. The RFID antenna is manufactured in China. Also, in China, final assembly occurs where the RFID module is embedded into the Chinese silicon bracelets. 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). Based on the facts presented, it is the opinion of this office that the secure microcontroller, which is manufactured in the Netherlands, is the main component of the finished RFID bracelets, since it is the component that transmits, controls, and stores the keycode data. The assembly processes that take place in China and the United States does not result in a substantial transformation of the microcontroller. Therefore, the subject RFID silicon bracelets would be considered a product of the Netherlands. 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 Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division