The country of origin of a PC gaming console

N359665 March 25, 2026 OT:RR:NC:N2:212 CATEGORY: Origin Michael Gamble Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a PC gaming console Dear Mr. Gamble: In your letter dated March 11, 2026, you requested a country of origin ruling on behalf of your client, Valve Corporation. The merchandise under consideration is the Steam Machine, which is further described as a Personal Computer (PC) gaming console. The device is cube-shaped in nature and consists of a Printed Circuit Board Assembly (PCBA) that contains the main processor, Graphics Processing Unit (GPU), system memory, and various other critical system components. The Steam Machine further incorporates an internal power supply, up to 2TB of storage, as well as Wi-Fi and ethernet connectivity. We note that this request only covers the console and no peripheral devices such as gaming controllers. The Steam Machine is a high-performance PC that runs on a Linux-based operating system. The device is designed to connect directly to the user’s TV or other monitor and allows access to the Steam video game library, allowing users to play, download, and manage games. The device can further act as a fully functioning PC as the user can install applications or alternative operating systems, browse the web, and expand the speed and functionality. In your request, you state that the manufacturing process begins with the creation of the main PCBA, or motherboard, in Thailand. This process is completed via Surface Mount Technology (SMT) and includes the placement of the main processing unit, GPU, memory, and other critical components. This motherboard is then sent to China. In China, the chassis, thermal module, and power supply are assembled to create the housing. The motherboard is then installed within the housing with various other supporting PCBAs, including the connection boards, power button board, and video conversion board. We note that the system RAM and SSD are sourced from Taiwan, Korea, and Japan. The finished console is then packaged for shipment 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). Regarding the origin of the subject device, it is the opinion of this office that the motherboard, which contains the essential functional components of the console, imparts the character of the finished article. Further, this PCBA is not substantially transformed into a new and different article of commerce by the processes performed in China. Based upon the facts presented, the country of origin for the Steam Machine will be Thailand. 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division