OT:RR:NC:N2:212
Joe Castillo
Razer (Asia-Pacific) Pte. Ltd.
1 One-North Crescent #02-01
Singapore 138538
Singapore
RE: The country of origin of a streaming controller
Dear Mr. Castillo:
In your letter dated June 11, 2026, you requested a country of origin ruling.
The merchandise under consideration is identified as the Razer Stream Controller X, model number
RZ20-04790100-R3U1, which is further described as an all-in-on customizable desktop keypad. The subject
device is comprised of a printed circuit board assembly (PCBA) within an enclosure. On the front of the
enclosure there are 15 programmable LCD membrane buttons. The device is further equipped with USB
connection points. In use, the device is attached to a PC, or other computer, allowing the user to manage and
control streaming content. The membrane buttons can be programmed with shortcuts for streaming, editing,
music production, among a variety of others. These can control the applications, lights, audio, and other
functions within the PC via the programmable buttons, which will display the appropriate icon via the LCD.
In your request, you state that the manufacturing process begins with the creation of the PCBA, via surface
mount technology (SMT), in Thailand. The individual components, such as integrated circuits, switches,
transistors, etc., are mounted onto the board and soldered in place. This creates the finished PCBA, which
contains the main processor and controls the device operation and functionality. The finished PCBA is then
sent to China where it is placed within the enclosure and the keypad is attached. The finished device is then
inspected, tested, and packaged 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).
Regarding the origin of the subject keypad, it is the opinion of this office that the PCBA imparts the character
of the finished device as it incorporates the core functionality of the finished device. Further, the processes
performed in China are simple in nature and would not substantially transform the Thai PCBA into a new and
different article of commerce. As such, the country of origin of the Razer Stream Controller X, model
number RZ20-04790100-R3U1, will be Thailand.
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