OT:RR:NC:N2:208
Joe Castillo
Razer (Asia-Pacific) Pte. Ltd.
1 One-North Crescent #02-01
Singapore 138538
Singapore
RE: The country of origin of gaming laptops
Dear Mr. Castillo:
In your letter dated December 15, 2025, you requested a country of origin ruling on five models of gaming
laptops.
The merchandise under consideration is identified as five models of automatic data processing (ADP)
machines that you refer to as Razer Blade 16 Gaming Laptop personal computers (PCs), models
RZ09-05817EN3-R3U1, RZ09-05818EN3-R3U1, RZ09-05818EN4-R3U1, RZ09-05819EN4-R3U1, and
RZ09-05819EN9-R3U1, which are all laptops equipped with Windows 11 Home NexGen Premium Edition
operating system and Razer Synapse. All models utilize the Intel Core Ultra X9 processor 386H. All models
have three USB Type-A ports, two USB4 Type-C Ports, one MicroSD card reader (UHS-II), and one HDMI
2.1 output. Moreover, each model in question has the same appearance, but has variations in the memory
size, GPU type, and storage capacity, based on the model configurations.
In your submission, you state that the manufacturing process for all five models of the Razer Blade 16
gaming laptops is the same. The motherboard printed circuit board assemblies (PCBAs) are assembled in
Vietnam using components sourced from various countries of origin. The production of the subassembly
PCBA motherboards starts with a blank PCB and advances through many steps completed by various
machines to create finished motherboard PCBAs. This production process includes the following steps:
surface mount technology (SMT), laser etching, solder paste application, accurate pick and placement of
small parts, permanent connection of the parts through a reflow oven, auto-inspection, and testing.
Once the motherboard PCBAs are tested and completed, they are then shipped to China where the Razer
Blade 16 gaming laptops are assembled. Each assembly process consists of inserting the PCBA into the
shell/cover and attaching other parts, such as the display panel, keyboard, storage, Wi-Fi antenna, webcam,
cooling fans, touch pad, speaker, battery, into the housing, as well as installing software. Lastly, these laptop
PCs are inspected, tested, labeled, and are packaged for export into the United States.
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).
Regarding the country of origin of the Razer Blade 16 Gaming Laptop person computers (PCs), the assembly
of the motherboard PCBAs in Vietnam, via surface mount technology (SMT), laser etching, solder paste
application, accurate pick and placement of small components, and permanent connection of the components
though a reflow oven, results in a substantial transformation of those components to produce fully
functioning motherboard PCBAs of Vietnam origin. Furthermore, it is the opinion of this office that the
motherboard PCBAs are the dominant component of the laptop PCs. The assembly work conducted in
China, which entails inserting, plugging, and fastening, does not substantially transform the motherboard
PCBAs into a new and different article. Therefore, we find that the Razer Blade 16, model numbers
RZ09-05817EN3-R3U1, RZ09-05818EN3-R3U1, RZ09-05818EN4-R3U1, RZ09-05819EN4-R3U1, and
RZ09-05819EN9-R3U1 are considered products of Vietnam for origin 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 Lisa Cariello at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division