RE: The country of origin of radio control transmitters

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 N365581 October 15, 2026 OT:RR:NC:N2:208 CATEGORY: Origin Brian Murphy Miller & Company, P.C. 4929 Main Street Kansas City, MO 64112-2631 RE: The country of origin of radio control transmitters Dear Mr. Murphy: In your letter dated September 30, 2026, you requested a country of origin ruling on behalf of your client, Horizon Hobby, LLC. The merchandise under consideration consists of radio control transmitters, models iX14+ and iX14+SE, items SPMR14010A and SPMR14020A. These handheld radio controllers remotely control toy aircraft, using a 2.4 GHz radio frequency (RF). Models iX14+ and iX14+SE are each comprised of approximately 100 unique components manufactured in a variety of countries. According to the information provided, the three main printed circuit board assemblies (PCBAs), the Plano RF Transmitter Module, the MBA Main Computer, and the Waco Receiver are manufactured in the United States (U.S.) through surface-mount technology (SMT) and dual in-line package (DIP)/wave-soldering processes. These processes consist of populating a printed circuit board (PCB) with various electrical and electronic components, including resistors, capacitors, fuses, and radiofrequency (RF) chips. These printed circuit board assemblies (PCBAs) generate radiofrequency signals and perform transmission, control, and reception functions. All non-China origin components including the Plano RF Transmitter Module PCBA, MBA Main Computer PCBA, and Waco Receiver PCBA will be shipped to China for final assembly. The Android System-on-Module (SOM) touch-screen graphical user interface (GUI), the trim PCBA, the CBA PCBA, and the printed circuit boards containing magnetic encoders are all manufactured in China. These boards perform secondary functions. The subject radio remote-control transmitters also contain a Chinese-origin Android SOM that includes a touch-screen user interface and a Wi-Fi/Bluetooth module. According to the information provided, the Android SOM serves only as a user interface for adjusting parameters on the MBA and is not involved in RF transmission, control, or reception functions. In China, the following final-assembly operations will be performed: the Chinese-origin plastic housing will be screwed and snapped together; gimbals or sticks will be screwed, press-fit, and soldered to wire harnesses; cables and switches will be soldered and press-fit into the housing; the Chinese-origin LCD screen will be screwed into the plastic housing and connected to cables; PCBAs will be installed in the plastic housing; and software and firmware will be loaded. Next, the Chinese-origin PCBAs will be installed; the antenna will be assembled and connected; the vibrator motor, speaker, and battery will be installed; decals will be applied; and testing will be performed. Lastly, the finished radio-control transmitters will be packaged. 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). Based on the information provided, it is the opinion of this office that the Plano RF Transmitter Module PCBA, the MBA Main Computer PCBA, and the Waco Receiver PCBA are the principal components of the finished radio remote control transmitters because they transmit RF control signals and communicate with the receiver. The complex SMT process used to manufacture these PCBAs, which includes placing numerous individual components onto a bare PCB, creates functional PCBAs and results in the substantial transformation of the components into PCBAs of U.S. origin. Additionally, the assembly operations performed in China do not substantially transform these PCBAs of U.S. origin into a new and different article of commerce with a name, character, or use distinct from that of the exported goods. Accordingly, we find that the country of origin of models iX14+ and iX14+SE, items SPMR14010A and SPMR14020A, is the United States. Whether an article may be marked with the phrase “Made in the USA” or similar words denoting U.S. origin is a matter under the jurisdiction of the Federal Trade Commission (FTC). We suggest that you contact the FTC’s Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508, regarding any marking indicating that an article is made in 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 Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division