The country of origin of radiofrequency (RF) remote control transmitters

N358589 March 2, 2026 OT:RR:NC:N2:208 CATEGORY: Origin Brian Murphy Miller & Co 4929 Main Street Kansas City, MO 64112 RE: The country of origin of radiofrequency (RF) remote control transmitters Dear Mr. Murphy: In your letter dated February 5, 2026, you requested a country of origin ruling on behalf of your client Horizon Hobby, LLC. The merchandise under consideration is radio frequency (RF) remote control transmitters, models NX8+ (I tem No. SPMR8210A) and NX10+ (Item No. SPMR10120A). These handheld radio controllers are used to control remote-controlled airplanes from a distance. These radio remote control transmitters are comprised of components that are manufactured in a variety of countries. They contain three printed circuit board assemblies (PCBAs): a Plano RF transmitter module PCBA, an MBA main computer PCBA, and a Waco Receiver PCBA. These PCBAs perform RF transmission, reception, control, and analog to digital processing functions. As per the information provided, all three PCBAs will be manufactured in the United States (U.S.) using surface mount technology (SMT). This process encompasses dual in-line packaging (DIP) and wave soldering, including populating a bare printed circuit board (PCB) with various electrical and electronic components (resistors, capacitors, fuses, RF chips, etc.) through solder paste printing, pick-and-place, solder reflow, automated optical inspection, x-ray inspection, etc. Next, the completed PCBAs are tested and firmware is added. They are then shipped to China for final assembly. In China, the following assembly operations occur: plastic housing will be screwed and snapped together, gimbals or sticks will be screwed, pressed, and soldered with wire harnesses, cables and switches will be soldered and press-fit into housing, the LCD screen will be screwed into the plastic housing and attached to the cables, the PCBAs will be attached into plastic housing, software will be installed and firmware will be updated, the battery will be added, decals will be applied, and functional testing will be done. Lastly, the radio control transmitters will be packaged and shipped. 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 information provided, it is the opinion of this office that the PCBA contributes to the main functionality of the finished radio remote transmitters. The complex SMT manufacturing production of these PCBAs, which includes the placement of numerous individual components onto a bare PCB, creates functional PCBAs that result in a substantial transformation of the components to produce PCBAs of U.S. origin. Additionally, the assembly process performed in China would not substantially transform the PCBAs of U.S. origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, we find that the country of origin for these radiofrequency (RF) remote control transmitters, models NX8+ (Item No. SPMR8210A) and NX10+ (Item No. SPMR10120A) are the United States. Whether an article may be marked with the phrase "Made in the USA" or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of proposed markings indicating that an article is made in the USA. 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