The country of origin of wired earbuds

N357686 February 4, 2026 OT:RR:NC:N2:209 CATEGORY: Origin Jimmy Lee 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. Lee: In your letter dated January 10, 2026, you requested a country of origin ruling on wired earbuds on behalf of you client, Sakar International, Inc. The merchandise under consideration is referred to as 28E03 Wired Earbuds With Microphone. These are wired earbuds that incorporate two earbuds/speakers at one end of a length of cable, an inline microphone, 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 user’s ears. Several components are manufactured in China: metal speaker case audio plug (jack) silicone caps polyurethane enameled wire (cable raw material) The remaining components are manufactured in Vietnam: wire (cable) manufacturing speaker microphone and button PVC material (cable raw 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, inline microphone and button, 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. The intersection of the “Y” or “Y-split” is reinforced with an 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 to the finished commodity by assembling it with the remaining components. The speakers are soldered onto the cable, then their housings and silicon earbud pads are added. The final assembly is then tested again and packed for export 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). Based on the facts presented, it is the opinion of this office that the character of the finished wired earbuds is imparted by the Vietnamese origin speakers, which would be considered the dominant component. Additionally, all other major components (cable assembly, and microphone with button) are also manufactured in Vietnam, and the final manufacturing/assembly steps are undertaken in Vietnam. As such, the country of origin of the finished 28E03 Wired Earbuds With Microphone will be Vietnam. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division