The tariff classification, country of origin, and eligibility of the United States-Mexico-Canada Agreement (USMCA) of gaming PCs from Canada

N359807 April 14, 2026 CLA-2-84:OT:RR:NC:N2:212 CATEGORY: Classification, Trade Programs, Origin TARIFF NO.: 8471.50.0150 Kevin Jia Quoted Technology Corporation 4075 Gordon Baker Rd. Toronto M1W 2P4 Canada RE: The tariff classification, country of origin, and eligibility of the United States-Mexico-Canada Agreement (USMCA) of gaming PCs from Canada Dear Mr. Jia: In your letter dated March 17, 2026, you requested a binding ruling on the tariff classification, country of origin, and eligibility of gaming PCs under the United States-Mexico-Canada Agreement (USMCA). There are five items at issue with this request, which are all described as gaming computers and individually identified below: Shield Gaming Computer: QTSHGC001 Custom Build Gaming Computer: QTCBGC001 Horizon Gaming Computer: QTHZGC001 Great North Gaming Computer: QTGNGC001 Frontier Gaming Computer: QTFTGC001 The subject devices are substantially similar in function and are each designed as a traditional desktop personal computer (PC). These devices further incorporate a motherboard with CPU, memory/storage, advanced GPUs, cooling apparatus and various other incidental components. The gaming PCs can function as traditional PCs and perform general purpose computing functions. However, the articles are specifically designed and marketed with advanced graphics cards in order to effectively run intensive gaming applications. In your request, you state that the assembly process for all five devices is identical and is performed in Canada using a variety of non-originating components. The motherboard and CPU are sourced from Vietnam. In Canada, the CPU is placed by hand onto the motherboard. The storage modules, DRAM, and cooling module, which originate from Korea and China are also installed onto the board. The finished board is then installed within the chassis with the power supply, which both originate from China, along with various cables. The finished PC is then flash programmed with the appropriate operating system, BIOS, and other software. The finished device is then packaged for shipment to the U.S. Classification: Though classification is not a specific issue to this request, we note that in order for this office to accurately examine the applicability of the subject trade agreement, we must accurately reflect the correct classification under the Harmonized Tariff Schedule of the United States (HTSUS). The applicable subheading for the gaming PCs, part numbers QTSHGC001, QTCBGC001, QTHZGC001, QTGNGC001, and QTFTGC00, will be 8471.50.0150, HTSUS, which provides for “Automatic data processing machines and units thereof… Processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units: Other.” The general rate of duty will be Free. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. USMCA: The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (“GN”) 11, HTSUS, implements the USMCA. GN 11(a) provides that: Goods that originate in the territory of Mexico, Canada or the United States (hereinafter referred to as “USMCA country” or “USMCA countries” as further defined in subdivision (l)(xxiv) of this note) under the terms of subdivision (b) of this note and regulations issued by the Secretary of the Treasury (including Uniform Regulations provided for in the USMCA), and goods enumerated in subdivision (p) of this note, when such goods are imported into the customs territory of the United States and are entered under a subheading for which a rate of duty appears in the “Special” subcolumn, followed by the symbol “S” in parentheses, are eligible for such duty rate, in accordance with section 202 of the United States-Mexico-Canada Agreement Implementation Act. Accordingly, if all other requirements are satisfied, merchandise imported into the United States will qualify for preferential tariff treatment under the USMCA if it meets one of the origin criteria enumerated in GN 11(b) or if it is classified in a provision listed in GN 11(p). In this case, an examination of the facts presented show that all of the components are sourced from outside of the USMCA territory and assembled using simple processes. Furthermore, the bulk of these components are classified within headings 8471 and 8473, HTSUS. As such, the requirements set forth in GN 11(b) are not met. GN 11(p) provides that: Notwithstanding any other provisions of this note, the following goods named in the first column below and classified in the provisions enumerated in the second column shall be deemed to be originating goods when imported into the customs territory of the United States from another USMCA country: Digital processing units……..8471.50 Based upon the facts provided, the finished PCs would be considered digital processing units. The subject devices contain advanced graphics processing units that allow them to effectively process and run intense gaming and other computing applications. Further, the devices are marketed and sold for their ability to perform advanced processing at high rates of speed. As such, the subject gaming PCs are deemed eligible for preferential treatment under the USMCA when imported into the U.S. Country of Origin: 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 gaming PCs for trade remedy purposes, it is the opinion of this office that the motherboard and CPU impart the character of the finished device. The attachment of the CPU to the motherboard is simple in nature and neither component would be substantially transformed by this process. Furthermore, the remainder of the processes performed are equally simple and would not effect a substantial transformation per previously established precedence. The country of origin for trade remedy purposes of the gaming PCs 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division