The country of origin of an Internet Protocol (IP) camera

N358367 February 20, 2026 OT:RR:NC:N2:208 CATEGORY: Origin Won-Bong Lee Dae Haa Customs Agency Corp. 10, Baekseokgongdan 1-ro, Seobuk-gu, Chungcheongnam-do Room 802, Bldg. A, Cheonan Mirae Ace High Tech City Cheonan-si 31094 Korea, South RE: The country of origin of an Internet Protocol (IP) camera Dear Mr. Lee: In your letter dated January 30, 2026, on behalf of your client Eyecloud Korea, you requested a country of origin ruling. The merchandise under consideration is an Internet Protocol (IP) Camera, model EC IPC -YYNT04-M2520-POE, which is a network-based CCTV camera designed for outdoor monitoring applications. This 4K IP camera is used to monitor traffic flow and vehicle behavior. The components are sourced from various countries (China, Taiwan, Japan, and South Korea). The Power over Ethernet (PoE) Board, which is manufactured in South Korea, is used for power and data transmission. The image sensor board and the image signal processor (ISP) board are both manufactured in China and perform the function of capturing, processing, and compressing images. In South Korea, the assembly process takes place. First, the Korean PoE board, the Chinese image sensor and ISP boards are attached to brackets by screw fastening. Next, the connector assembly is added, and the electrical signal verification takes place. After that, the Taiwanese lens and Chinese IR filter assembly are affixed to the boards. Then, the board modules and optical devices are connected using brackets and bolts and the housing is added. Lastly, testing, firmware upgrade, optical re-verification, packaging, etc. are done. 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 image sensor board and ISP Board, which are made in China, contribute to the main functionality of the finished IP camera. The assembly processes that take place in South Korea do not result in a substantial transformation of the image sensor and the ISP boards. Accordingly, the IP camera, model EC IPC -YYNT04-M2520-POE, would be considered a product of China for origin purposes at the time of importation into the United States. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division