OT:RR:NC:N2:220
Katherine Tran
Lite-On Vietnam Co. Ltd.
No. 149, 10th Road, VSIP Hai Phong Township
Industrial and Service Park
Lap Le Ward, Hai Phong 180000
Vietnam
RE: The country of origin of a switching power supply
Dear Ms. Tran:
In your letter dated March 11, 2025, you requested a country of origin ruling on behalf of your client, Cooler
Master USA.
The merchandise under consideration is identified as the Switching Power Supply MWE Gold 850W V3, PN
PS-5851-3CX,which is described as a metal enclosure having five internally mounted printed circuit board
assemblies (PCBAs), numerous electrical connectors, a cooling fan, multiple wire harnesses, and heat sinks.
The power supply is used as a primary source of power for personal computers. The first PCBA, noted as the
Motherboard, converts AC electricity to DC. The second PCBA provides for the interface and control of
switches and signals. The third PCBA is described as a voltage conversion board. The fourth PCBA is
described as a fan control board. The fifth PCBA is described as the power output board.
In your letter, you state that the PCBAs are all assembled in Vietnam by soldering numerous individual
components of various origins, such as capacitors, resistors, integrated circuits, transistors, connectors, relays,
diodes, transformers, chokes, and more onto bare printed circuit boards by a surface mount and through hole
insertion process. Also in Vietnam, the power supply is assembled, tested, and packaged for export.
When determining the country of origin, 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).
Regarding the origin of the subject power supply, the assembly of the PCBAs in Vietnam by soldering the
individual components of various origins onto bare boards results in a substantial transformation of those
components to produce the five PCBAs of Vietnamese origin.? Furthermore, it is the opinion of this office
that the Motherboard PCBA establishes the function of the power supply because it is the article within the
assembly that converts the electricity from AC to DC.? As a result of the foregoing, we find that the
components that make up the power supply are substantially transformed in Vietnam into a new and different
article of commerce, and the Switching Power Supply MWE Gold 850W V3, PN PS-5851-3CX, is
considered a product of Vietnam for origin purposes at 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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division