H351954

H351954 January 22, 2026 OT:RR:CTF:VS H351954 RMC CATEGORY: Origin Yeshwin Gunanithi Epifeast Inc. 1401 21st St., Suite 11835 Sacramento, CA 95811 RE: Country of Origin and UKFTA Eligibility of the Posha Autonomous Cooking Appliance Dear Mr. Gunanithi: This is in response to your correspondence of July 25, 2025, in which you ask U.S. Customs and Border Protection (“CBP”) to address the country of origin of the Posha autonomous cooking appliance (“Posha”) and its eligibility for preferential tariff treatment under the United States-Korea Free Trade Agreement (“UKFTA”). Your request, submitted as an electronic ruling request, was forwarded to this office from the National Commodity Specialist Division for response. We determined that certain information submitted in connection with this internal advice request should be treated as confidential. Therefore, pursuant to the requirements of 19 C.F.R. §177.2(b)(7), the information contained within brackets and all attachments to this internal advice request, forwarded to our office, will not be released to the public and will be withheld from published versions of this decision. FACTS: You describe Posha as a “private robot chef” or as “an intelligent, countertop autonomous cooking appliance that automates the preparation of full meals.” You state that it is classified in subheading 8516.60.40, Harmonized Tariff Schedule of the United States (“HTSUS”). To use the device, the user selects a recipe on Posha’s screen or on the companion mobile application. The recipe will indicate the names and quantities of the ingredients (spices, produce, meat, etc.) that the user must load into the device. Once the user instructs Posha to begin, the device will complete the meal autonomously, adding ingredients, stirring as needed, seasoning the food, and controlling the cooking temperature. Posha is composed of five main components: (1) a macro dispensing system for solid ingredients; (2) a micro dispensing system for spices and powders; (3) a software-controlled induction burner; (4) a motorized stirrer assembly synchronized with recipe logic; and (5) an integrated camera and LED system for food detection and processing monitoring. The following bill of materials was provided: Group Material Quantity Country of Originating Classification Value Name Origin Status (USD) (Per Unit) Core Electronic Motherboard 1 China or Non 8473.30.11 $[ ] Assemblies Printed Korea Originating Circuit or Board Originating Assembly (“PCBA”) (with System on Module) Induction 1 China or Non 8473.30.11 $[ ] Board PCBA Korea Originating or Originating Power & Induction 1 China Non 7409.11.10 $[ ] Heating Coil Originating Components Ceramic 1 China Non 7020.00.60 $[ ] Glass Originating Cooking Surface SMPS 1 China Non 8504.40.95 $[ ] (Switched- Originating Mode Power Supply) Power Entry 1 China Non 8536.69.80 $[ ] Connector Originating Mechanical Subassemblies Macro Assembly Macro arm 4 China Non 7308.30.10 $[ ] structure Originating Servo 4 China Non 8501.10.40 $[ ] motors Originating Macro dock 4 China Non 3926.90.99 $[ ] Originating Pan 1 China Non 3926.90.99 $[ ] enclosure Originating (bottom) 2 Pan 1 China Non 3926.90.99 $[ ] enclosure Originating (top) Macro 1 China Non 8473.30.11 $[ ] breakout Originating board Micro 1 China Non 3926.90.99 $[ ] drawer base Originating Carousel 1 China Non 3926.90.99 $[ ] Originating Carousel 1 China Non 8501.10.40 $[ ] Motor Originating Dispending 1 China Non 8501.10.40 $[ ] Motor Originating Sensor 1 China Non 8543.70.45 $[ ] Originating Sensor 1 China Non 8473.30.11 $[ ] Originating Micro 1 China Non 8473.30.11 $[ ] Breakout Originating Board Stirrer Assembly Stirrer Arm 1 China Non 8509.40.00 $[ ] Originating Stirrer Motor 1 China Non 8501.10.40 $[ ] (BLDC) Originating Pulleys 2 China Non 8483.50.90 $[ ] Originating Belt 1 China Non 4010.39.10 $[ ] Originating Magnetic 2 China Non 8536.69.80 $[ ] Connector Originating Gear 2 China Non 7308.30.10 $[ ] Housing Originating Stirrer 1 China Non 8544.42.90 $[ ] Harness Originating Display & Display 1 Taiwan Non 8531.20.00 $[ ] Vision System Assembly Originating Camera 1 China Non 8525.89.40 $[ ] Module Originating LED Strip 2 China Non 9405.42.82 $[ ] Assembly Originating Fluid Handling Pumps 2 China Non 8413.50.00 $[ ] System Pumps (Oil/Water) Originating Pipes / 6 China Non 3917.29.00 $[ ] Tubing Originating (rubber) 3 Flow Meter 2 China Non 9026.10.40 $[ ] Originating Structural & Base Frame 1 China Non 7308.30.10 $[ ] Enclosure (metal) Originating Components Metal Top 1 China Non 7308.30.10 $[ ] Cover Originating Rubber Feet 4 China Non 4016.93.10 $[ ] Originating Rollers 4 China Non 8482.10.10 $[ ] Originating Plastic Front Cover 1 China Non 3926.90.99 $[ ] Enclosure Parts Originating Rear Cover 1 China Non 3926.90.99 $[ ] Originating Left Cover 1 China Non 3926.90.99 $[ ] Originating Right Cover 1 China Non 3926.90.99 $[ ] Originating Cable 1 China Non 8544.42.90 $[ ] Originating Usables Fasteners 60 China Non 7318.15.20 $[ ] Originating Zip Ties 20 China Non 3926.90.99 $[ ] Originating Adhesive 1 China Non 3919.10.20 $[ ] Tape Originating Retail 1 China Non 4819.10.00 $[ ] Packaging Originating Accessories Cooking Pan 1 China Non 7323.93.00 $[ ] Originating Spatulas 3 China Non 8215.91.90 $[ ] Originating Containers 4 China Non 3923.90.00 $[ ] Originating AC Power 1 China Non 8544.42.90 $[ ] Cord Originating Spice Pods 12 China Non 3926.90.99 $[ ] Originating Manual 1 China Non 4901.99.00 $[ ] Originating Three production scenarios are presented in the ruling request. In all three scenarios, one of the five main components (the integrated camera and LED system) is assembled in Taiwan. Then, depending on the scenario, the remaining production and assembly will occur between China and Korea. 4 In the first scenario (“Scenario A”), the motherboard PCBA and induction board PCBA are made in China through surface mount technology (“SMT”). Each of the remaining subassemblies is then assembled in China, which generally involves fastening components, wiring connectors, and performing visual inspections. The subassemblies are then fitted together, before Indian-origin firmware is loaded onto the device. The device then undergoes final testing in Korea before being placed in a box for shipment from Korea to the United States. In the second scenario (“Scenario B”), as in Scenario A, the motherboard PCBA and induction board PCBA are made in China through SMT. However, assembly of the stirrer assembly, macro dispensing system, and micro dispensing system occurs in Korea with the same processing (fastening components, wiring connectors, and performing visual inspections). The remaining production steps, including fitting the subassemblies together, loading the Indian-origin software, testing, and packaging, occur in China. The goods are then sent directly from China to the United States. In the third scenario (“Scenario C”), the motherboard PCBA and induction board PCBA are made in Korea through SMT. All remaining production steps as described for the previous production scenarios then occur in China, and the goods are shipped directly from China to the United States. In your ruling request, you ask us to determine the country of origin of Posha and its eligibility for preferential tariff treatment under the UKFTA. ISSUES: I. What is the country of origin of Posha when imported into the United States? II. Whether Posha is eligible for preferential tariff treatment under the UKFTA when it is imported into the United States. LAW AND ANALYSIS: I. Country of Origin 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 countr

I. Country of Origin 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. 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 goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & 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 5 

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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). In order to determine whether a substantial transformation occurs when co