In ruling NY N305154, Customs and Border Protection (CBP) determined the classification and country of origin of a Roomba® “670 Series Robotic Vacuum Cleaner.”  The item is a Wi-Fi connected vacuum robot used to clean floors. Its cleaning system allows it to loosen, lift and suction dirt, dust and hair from hard floors and carpet. The set includes the Roomba® vacuum robot, a rechargeable battery, a docking station for recharging and a power cord.

CBP determined that the applicable subheading for the item in question is 8508.11.0000, which provides for Vacuum cleaners; parts thereof: With self-contained electric motor: Of a power not exceeding 1,500 W and having a dust bag or other receptacle capacity not exceeding 20 l.  The rate of duty will be Free.

The Roomba® vacuum robot consists of approximately one thousand components, many of which are first fabricated into module subassemblies manufactured in Malaysia.  These modules will then be further fabricated into the Roomba® chassis and connected to and programmed with the Main Printed Circuit Board which contains all the required operational software, resulting in the finished Roomba®.  The manufacturing process will include the production of four separate key module subassemblies in Malaysia.  Each of these modules is a significant component of the finished Roomba®.  The modules will consist of components of several origins, with the majority being Malaysia content.  Three of the modules will be manufactured in China and shipped to Malaysia. The key modules either assembled or substantially transformed in the Malaysian factory include Main Printed Circuit Board, Wheel Modules, Cliff Harness Module and Bin Module.  These modules are fabricated into the chassis housing to create the complete Roomba® vacuum cleaner.  The chassis houses and protects all components of the Roomba® vacuum cleaner.

19 C.F.R. § 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”.

Based on the information submitted, the materials/components and subassemblies imported into Malaysia from China where they are manufactured into different subassemblies, which are ultimately assembled into the subject Roomba®.

CBP believes that the processing performed in Malaysia with respect to Roomba®  constitutes a substantial transformation of the imported materials/components.  The manufacturing process in Malaysia transforms the Chinese originating components/materials to produce the finished product.  CBP concludes that the country of origin for the Roomba® and accessories when imported together will be Malaysia.