OT:RR:NC:N2:212
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin and marking of a PC game console bundle
Dear Ms. Murrin:
In your letter dated April 14, 2026, you requested a country of origin and marking ruling on behalf of your
client, Valve Corporation.
The merchandise under consideration is the Steam Machine Bundle, which you state is a kit containing the
Steam Machine Personal Computer (PC) gaming console and a handheld controller. The Steam Machine
console is cube-shaped in nature and consists of a Printed Circuit Board Assembly (PCBA) that contains the
main processor, Graphics Processing Unit (GPU), system memory, and various other critical system
components. The Steam Machine further incorporates an internal power supply, up to 2TB of storage, as well
as Wi-Fi and ethernet connectivity. The incorporated controller is the input device for the console and
consists of an internal PCBA, trigger mechanisms, haptics, and buttons within a plastic housing.
The Steam Machine is a high-performance PC that runs on a Linux-based operating system. The device is
designed to connect directly to the user’s TV or other monitor and allows access to the Steam video game
library, allowing users to play, download, and manage games. The device can further act as a fully
functioning PC as the user can install applications or alternative operating systems, browse the web, and
expand the speed and functionality.
In your request, you describe the manufacturing process for both the console and the controller. Regarding
the console, you state that the manufacturing process begins with the creation of the main PCBA, or
motherboard, in Thailand. This process is completed via Surface Mount Technology (SMT) and includes the
placement of the main processing unit, GPU, memory, and other critical components. This motherboard is
then sent to China. In China, the chassis, thermal module, and power supply are assembled to create the
housing. The motherboard is then installed within the housing with various other supporting PCBAs,
including the connection boards, power button board, and video conversion board. We note that the system
RAM and SSD are sourced from Taiwan, Korea, and Japan.
For the controller, you state that the main PCBA is manufactured via SMT in China. Various other electronic
components, such as a trackpad and adapter board, are also manufactured in China. These components are
then combined with the thumbstick module and various plastic and metal components. Finally, these
components are enclosed within a plastic housing along with the battery and charging module. The finished
controller and console are then packaged in one box together and prepared for 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).
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. The 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 good is 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.
It is the opinion of this office that the main PCBA, or motherboard, of the Steam Console represents the
essential functional component of the console and imparts the character of the device. Further, the PCBA is
not substantially transformed by the processes performed in China. As such, the country of origin of the
Steam Console is Thailand.
The essential character of goods classified as a set, or where no single manufacturing process provides a clear
"substantial transformation," is determined by the origin based on the single component that imparts the
essential character to the finished product. Since the Stream Console imparts the essential character of this
bundle, its origin dictates the origin of the entire set. Therefore, the country of origin of the bundle is
Thailand.
Please note that pursuant to the marking statute, Section 304, Tariff Act of 1930, as amended (19 U.S.C.
1304), unless excepted, every article of foreign origin (or its container) imported into the U.S. 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 U.S. the English name
of the country of origin of the article. Part 134, Customs Regulations (19 CFR Part 134), implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.41(b), Customs
Regulations (19 CFR 134.41(b)), mandates that the ultimate purchaser in the U.S. must be able to find the
marking easily and read it without strain. Section 134.1(d), defines the ultimate purchaser as generally the
last person in the U.S. who will receive the article in the form in which it was imported. If an imported
article is to be sold at retail in its imported form, the purchaser at retail is the ultimate purchaser.
As to the marking of the Steam Console Bundle that is comprised of articles manufactured in different
countries and packaged together for import and retail sale as a set, we look to the Treasury Decision (T.D.)
91-7, published in Volume 25, Customs Bulletin and Decisions, at 6 (January 16, 1991), which addressed,
among other things, the application of country of origin marking requirements to sets. It was stated therein, at
16:… in most cases, the mere inclusion of an item in a collection will not substantially transform it into an
article with a new name, character or use and, therefore, each item must be separately marked with its own
country of origin. (Where the marking of the container will reasonably indicate the country of origin to the
ultimate purchaser, the container may be marked instead of the individual articles. See 19 U.S.C.
1304(a)(3)(D) and 19 CFR 134.32(d)). This result is consistent with the purpose of the marking statute, since
the ultimate purchaser’s decision as to whether to buy the set might be influenced by the country of origin of
any of the items in the set, whether or not an item gives the set its essential character.
Within your request, you provide suggested marking of “Main Unit made in XXX” and “Accessories made in
XXX” as an alternative to “Console made in XXX” and “Controllers made in XXX.” As the bundles contain
specific products that have different countries of origin, we find that the retail packaging must indicate the
proper country of origin for each item in the set. As such, the packaging should be marked “Console made in
XXX” and “Controllers made in XXX.”
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 Luke LePage at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division