OT:RR:NC:N2:208
Xiao Yan
Solid Year Co., Ltd.
18F-11., No.97, Sec. 1, Xintai 5th Rd., Xizhi Dist.
New Taipei City 221416
Taiwan
RE: The country of origin of a Mechanical Keyboard (finished product version)
Dear Ms. Yan:
In your letter dated November 26, 2025, you requested a country of origin ruling for a Mechanical Keyboard
(finished product version), on behalf of your client, Wooting Store B.V.
The merchandise under consideration is identified as the Wooting 60HE+ Mechanical Keyboard, W05T011
(finished product version). The W05T011 (finished product version) comes packaged with the Wooting
60HE+ keyboard, USB-C cable, keycap puller, strap, two spare lekker switches, two spare screws, blister
(dust cover), and a postcard.
Based on the information provided, the subject finished mechanical keyboard is made up of individual
components, such as a microcontroller, hall-effect sensors, switches, a printed circuit board (PCB), a plastic
housing, stabilizers, and other subassemblies, which are sourced globally. In Taiwan, the various
components are placed onto the PCB using solder paste application, surface mount technology (SMT), and
through-hole assembly, creating a complete printed circuit board assembly (PCBA). Firmware is then added
and validated. The mechanical assembly of the keyboard housing, stabilizers, and case takes place next. The
finished keyboard is then tested and packaged for export.
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. 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. 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.
Based on the facts presented, it is the opinion of this office that the origin of the finished mechanical
keyboard is the country in which the PCBA is produced using solder paste application, SMT, and
through-hole assembly. The manufacturing process performed in Taiwan substantially transforms the
Chinese components into a mechanical keyboard. As a result, we find that the country of origin for marking
and trade remedy purposes of the Wooting 60HE+ Mechanical Keyboard, W05T011 (finished product
version), is Taiwan.
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 [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division