RE: The tariff classification and country of origin of the Cash Wand

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365357 October 13, 2026 CLA-2-85:N2:208 CATEGORY: Classification; Origin TARIFF NO.: 8523.59.0000 Chandra Martinez Block, Inc. 1955 Broadway, Ste. 600 Oakland, CA 94612 RE: The tariff classification and country of origin of the Cash Wand Dear Ms. Martinez: In your letter dated September 23, 2026, you requested a tariff classification and country of origin determination ruling. The merchandise under consideration is the Cash Wand, model number A-CSH-0020, which is a contactless payment device. This payment device consists of a plastic outer casing in the shape of a wand with a payment chip module embedded within it and attached to a clasp. It contains an integrated circuit (IC) that stores a code that enables consumers to make near-field communication (NFC) payments at point-of-sale terminals. Moreover, the secure microcontroller (payment chip) stores and transmits payment data when the device is read by an NFC-enabled payment terminal. The applicable subheading for the Cash Wand will be 8523.59.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides, in relevant part, for Other media for the recording of sound or other phenomena …: Semiconductor media: Other. The 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. The device undergoes a multi-country manufacturing process. Wafer fabrication occurs in Germany approximately 85 percent of the time or in Singapore as a backup when the German facility is at maximum capacity and unable to meet demand. According to the information provided, the secure microcontroller is manufactured through this wafer-fabrication process. Die cutting, dicing, and testing occur in Thailand. FPCB tag production, IC module assembly, IC packaging, final assembly of the finished module, and consumer packaging are performed in China. 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 (“HQ”) 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). Based on the facts presented, it is the opinion of this office that the secure microcontroller chip, which is manufactured in Germany or Singapore, is the main component of the finished wand. The complex manufacturing process involved in wafer fabrication results in a complete microcontroller that stores and transmits data. The assembly processes that take place in China and Thailand do not result in a substantial transformation of the microcontroller. Therefore, the subject Cash Wand, model number A-CSH-0020, would be considered a product of Germany or Singapore, depending on where the wafer fabrication is performed. 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