OT:RR:NC:N2:209
Jaden Kuo
PricewaterhouseCoopers Legal
25F, No. 333, Section 1, Keelung Road, Xinyi District
Taipei 110
Taiwan
RE: The country of origin of two pairs of USB wired headsets
Dear Mr. Kuo:
In your letter dated May 4, 2026, you requested a country of origin ruling on two pairs of USB wired
headsets.
The items concerned are two pairs of wired headsets referred to as HP Poly Mission 415 USB (D3+ Mono)
and HP Poly Mission 825 USB (D6 Stereo), which are both Hewlett Packard (HP) products, corresponding to
the 400 and 800 series, respectively.
The D3+ Mono is described as a lightweight, monaural (single ear) USB wired headset with a microphone.
This device connects to its intended device via a USB C cable (with USB C to USB A adapter attached) and
incorporates an inline control box on the cable.
In Taiwan, components originating from China, Taiwan, and the United States are placed and soldered onto
bare printed circuit boards (PCBs) via surface mount technology (SMT), forming the Inline Box printed
circuit board assembly (PCBA) and the Right Main Board PCBA. The Inline Box printed circuit board
assembly (PCBA) is responsible for the main control and processing functions (i.e., volume, mute, and
answer/end calls) and the Right Main Board PCBA, is the primary electronic circuitry used to interconnect
the boom mic, speaker, and inline box. The completed PCBAs are tested for functionality, then the speaker
assembly and inline box assembly are manufactured and tested. The completed PCBAs, speaker assemblies
and inline box assemblies are then shipped to Vietnam.
In Vietnam, the boom microphone is assembled and inserted onto the headband and the final mechanical
assembly takes place. The finished wired headphones are tested, inspected, packaged, and shipped to the
United States for retail sale.
The D6 Stereo is described as a lightweight stereo (double ear) USB wired headset with a microphone. This
device connects to its intended device via a USB C cable (with USB C to USB A adapter attached) and
incorporates an inline control box on the cable.
In Taiwan, components originating from China, Taiwan, and the United States are placed and soldered onto a
bare PCB via SMT, forming 6 separate PCBAs (the Inline Box PCBA, Left Main Board PCBA, Right Main
Board PCBA, two Feedback Microphone (FBMIC) PCBAs, and a Noise Cancelling (NC) LED PCBA). The
completed PCBAs are tested for functionality, then the speaker assembly and inline box assembly are created
and tested. The completed PCBAs, speaker assemblies and inline box assemblies are then shipped to Vietn
am.
In Vietnam, the boom microphone is assembled and inserted onto the headband. The final mechanical
assembly takes place. The finished wired headphones are tested, have their final inspection, packaged, and
shipped to the United States for retail sale.
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).
Based on the facts presented, it is the opinion of this office that the various PCBAs, speaker assemblies , and
inline box assemblies manufactured in Taiwan are the fundamental functional components of each headset.
The PCBAs form the control functions and main electronic circuitry, the speaker provides the essential audio
output, and the inline box provides complete inline control for the user. Together, they provide the core
functions of the headsets, providing the essence of the finished product. The assembly operations performed
in Vietnam will not change the character and end use of these products. Therefore, since substantial
transformation does not occur as a result of the processes performed in Vietnam, the country of origin for the
HP Poly Mission 415 USB and HP Poly Mission 825 USB Headsets would be Taiwan for marking purposes
and for the purposes of applying current trade remedies and additional duties.
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 Steven Pollichino at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division