The country of origin and marking of a PC game console bundle

N360699 April 29, 2026 OT:RR:NC:N2:212 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin and marking of a PC game console bundle Dear Ms. Murrin: In your letter dated April 14, 2026, you requested a country of origin and marking ruling on behalf of your client, Valve Corporation. The merchandise under consideration is the Steam Machine Bundle, which you state is a kit containing the Steam Machine Personal Computer (PC) gaming console and a handheld controller. The Steam Machine console 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. The incorporated controller is the input device for the console and consists of an internal PCBA, trigger mechanisms, haptics, and buttons within a plastic housing. 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 describe the manufacturing process for both the console and the controller. Regarding the console, 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. For the controller, you state that the main PCBA is manufactured via SMT in China. Various other electronic components, such as a trackpad and adapter board, are also manufactured in China. These components are then combined with the thumbstick module and various plastic and metal components. Finally, these components are enclosed within a plastic housing along with the battery and charging module. The finished controller and console are then packaged in one box together and prepared 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). 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. It is the opinion of this office that the main PCBA, or motherboard, of the Steam Console represents the essential functional component of the console and imparts the character of the device. Further, the PCBA is not substantially transformed by the processes performed in China. As such, the country of origin of the Steam Console is 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 Console 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 Console Bundle that is comprised of articles 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. Within your request, you provide suggested marking of “Main Unit made in XXX” and “Accessories made in XXX” as an alternative to “Console made in XXX” and “Controllers made in XXX.” As the bundles contain specific products that have different countries of origin, we find that the retail packaging must indicate the proper country of origin for each item in the set. As such, the packaging should be marked “Console made in XXX” and “Controllers made in XXX.” 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