The country of origin of a USB-C to Gigabit Ethernet Adapter

N362527 July 15, 2026 OT:RR:NC:N2:209 CATEGORY: Origin Jessica Chen Cable Technology Corp. 5F, No. 58, Zhongshan North Rd. Sec. 3 Taipei 104 Taiwan RE: The country of origin of a USB-C to Gigabit Ethernet Adapter Dear Ms. Chen: In your letter dated June 24, 2026, you requested a country of origin ruling on a USB-C to Gigabit Ethernet Adapter. The item concerned is identified as a USBC to Gigabit Ethernet Adapter, Item No. CT-530 (CT-530). The item is described as a short cable, enclosed in an aluminum housing, with a USB-C connector on one end and an RJ45 port connected to the other end. The manufacturing process begins in Taiwan with the production of the printed circuit board assembly (PCBA). The main component is called the ASIX Electronics AX88179B chipset, which is sourced from ASIX Electronics, a Taiwanese integrated circuit (IC) design company. Other passive electronic components, such as resistors, capacitors, etc., are sourced from Korea, China, and Taiwan. A laser-cut stainless steel stencil is prepared for the printed circuit board (PCB) layout. Solder paste is printed onto the PCB pads through the stencil. The ASIX chipset and other electronic components are placed onto the bare PCB. The board passes through a reflow oven, permanently soldering all components onto the board, forming a completed PCBA. The completed PCBA is shipped to China where a short cable is soldered onto the PCBA. A plastic end piece on the cable allows the aluminum housing to be fitted over the PCBA and clamped shut. The unit then goes through functional and visual testing. The finished product is shipped back to Taiwan for final inspection and packaging for importation into the United States. 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. 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 goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Based upon the facts presented, it is the opinion of this office that the assembly of the PCBA in Taiwan by soldering individual components to the bare PCB results in a substantial transformation of the components to produce a PCBA of Taiwanese origin. The work performed in China, of attaching the cable and aluminum housing to the PCBA is not complex and does not substantially transform the PCBA into a different article of commerce with a new name, character, and/or use. Therefore, the USBC to Gigabit Ethernet Adapter, Item No. CT-530 (CT-530) is considered a product of Taiwan for origin and marking purposes at the time of importation into the United States. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division