OT:RR:NC:N2:207
Gena Haddock
Expeditors Tradewin, LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin of a wireless charging stand
Dear Ms. Haddock:
In your letter dated February 17, 2026, you requested a country of origin ruling on a wireless charging stand
on behalf of your client, Anker Innovations Technology Co., Ltd.
The merchandise under consideration is described as a 3-in-1 Wireless Charging Station, model number
A25X7, which consists of a wireless charging stand with a USB-C charging cable and a 65W power adapter.
The wireless charging stand is comprised of a round base containing two mainboard Printed Circuit Board
Assemblies (PCBA) and an adapter board PCBA in the smartphone charging module. The three PCBAs are
interconnected to each other to facilitate the charging of earbuds, smartphones, and smart watches by
managing power distribution, coordinating device communication, and enabling user interface. The base also
features a display screen for showing various status indicators and a charging pad for earbuds. The center of
the base has a V-shaped support rod with a dedicated charging pad for smartphones on one arm and smart
watches on the other. The device allows the user to charge a smartphone, smart watch, and wireless earbuds
simultaneously.
In your submission, you state that the entire manufacturing process takes place in Vietnam using various
components sourced from China and Vietnam. The mainboard PCBAs and the adapter PCBA are produced
using a Surface Mount Technology (SMT) process to populate the bare Printed Circuit Board (PCB) with
various electronic components. Next, the wireless charging module for smartphones is assembled using an
induction coil from Vietnam with various components from China such as a cooling fan, magnet module, and
thermal pad as well as integrating the adapter board PCBA. The smart watch charging module is assembled
using a PCBA, magnet, and induction coil of Chinese origin. Finally, the base of the wireless charging stand
is assembled by soldering the two mainboard PCBAs together. Then the base is further assembled using a
Vietnamese origin induction coil for earbuds and integrated with multiple Chinese origin components such as
a display, Bluetooth antenna, thermal pad and other miscellaneous components. Then all subassemblies are
joined together using the V-shaped support rod at the center of the base with circuit cables routed to connect
all subassemblies creating the finished wireless charging stand. The finished product will be tested, inspected
and packaged with the charging cable and power adapter before shipment to 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 3-in-1 Wireless Charging Station, in our view the assembly of the two
mainboard PCBAs in Vietnam by mounting and soldering individual electronic components onto a bare PCB
using a SMT process results in a substantial transformation of the components to produce functional PCBAs
of Vietnamese origin. Furthermore, it is the opinion of this office that the Vietnamese origin PCBAs and
inductive charging modules establish the function of the electrical charging device because it is the article
within the assembly that regulates, converts and distributes electricity to the magnetically attached or placed
personal electronic devices. As such, we find that the components that make up the wireless charging stand
are transformed in Vietnam into a new and different article of commerce with a distinct name, character, and
use. Thus, the country of origin of the 3-in-1 Wireless Charging Station will be Vietnam 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 Howard Suh at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division