The country of origin and marking of a virtual reality headset bundle

N359663 April 6, 2026 OT:RR:NC:N2:208 CATEGORY: Origin Michael Gamble Expeditors Tradewin LLC 795 Jubilee Drive , Peabody, MA 01960 RE: The country of origin and marking of a virtual reality headset bundle Dear Mr. Gamble: In your letter dated March 11, 2026, on behalf of your client Valve Corporation you requested a country of origin ruling. The merchandise under consideration is the Steam Frame bundle, model number Deckard, which is a set consisting of a virtual reality headset, an eye relief spacer, two controllers, a USB Wi-Fi dongle, and a USB-C charging cable, packaged together for retail sale. The wearable device features a Qualcomm Snapdragon 8 Gen 3 processor with 16GB of RAM and dual 2160 x 2160 liquid crystal displays (LCD) with lenses offering up to a 110-degree field of view and refresh rates from 72Hz to 144Hz. Moreover, the Steam Frame headset includes inside-out tracking, eye-tracking, Wi-Fi 7 connectivity, 1TB of expandable storage, and a modified version of SteamOS. It is the opinion of this office that the Steam Frame headset imparts the essential character of this set. Based on the information provided regarding the manufacturing process of the Stream Frame headset, the main printed circuit board assembly (PCBA) is manufactured in Thailand. During this process, the main PCBA is populated with critical components, including the system on a chip (an integrated circuit that combines most key components of a computer or electronic system onto a single microchip), memory, connectors, resistors, etc., via surface-mount technology (SMT). The supporting subassemblies, such as the left and right eye tubes, camera modules, battery, speaker, and speaker box, are made in China. The final assembly also occurs in China. This process entails installing the main PCBA and the subassemblies into the headset's housing, adding additional components such as lenses, straps, and sensors, and loading firmware and software. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. The Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the good is produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Based on the facts presented, we conclude that the main PCBA provides the dominant component of the Steam Frame virtual reality headset since it performs key functions, such as data processing, power distribution, memory storage, and interfaces with the headset’s sensors, displays, and other peripherals. The assembly process performed in China would not substantially transform the main PCBA of Thai origin into a new and different article of commerce with a name, character, and use. Accordingly, the Steam Frame virtual reality headset bundles, which are referred to as “Deckard,” are products of Thailand. The essential character of goods classified as a set, or where no single manufacturing process provides a clear "substantial transformation," is determined by the origin based on the single component that imparts the essential character to the finished product. Since the Stream Frame headset imparts the essential character of this bundle, its origin dictates the origin of the entire set. Therefore, the country of origin of the bundle is Thailand. Please note that pursuant to the marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article. Part 134, Customs Regulations (19 CFR Part 134), implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs Regulations (19 CFR 134.41(b)), mandates that the ultimate purchaser in the U.S. must be able to find the marking easily and read it without strain. Section 134.1(d), defines the ultimate purchaser as generally the last person in the U.S. who will receive the article in the form in which it was imported. If an imported article is to be sold at retail in its imported form, the purchaser at retail is the ultimate purchaser. As to the marking of the Steam Frame and the Steam Frame Controllers that are manufactured in different countries and packaged together for import and retail sale as a set, we look to the Treasury Decision (T.D.) 91-7, published in Volume 25, Customs Bulletin and Decisions, at 6 (January 16, 1991), which addressed, among other things, the application of country of origin marking requirements to sets. It was stated therein, at 16:… in most cases, the mere inclusion of an item in a collection will not substantially transform it into an article with a new name, character or use and, therefore, each item must be separately marked with its own country of origin. (Where the marking of the container will reasonably indicate the country of origin to the ultimate purchaser, the container may be marked instead of the individual articles. See 19 U.S.C. 1304(a)(3)(D) and 19 CFR 134.32(d)). This result is consistent with the purpose of the marking statute, since the ultimate purchaser’s decision as to whether to buy the set might be influenced by the country of origin of any of the items in the set, whether or not an item gives the set its essential character. Since the subject bundles contain products sourced from different countries that have not been substantially transformed in either country, you will need to mark the retail packaging box to indicate the proper country of origin for each item in the set. Accordingly, the proposed marking of the container “Main Unit made in XXXX” and “Accessories made in XXXX” is not acceptable. The package must provide the proper country of origin marking for each item in the imported container. 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 P. Forkan Director National Commodity Specialist Division