The country of origin determination of an LED light string from China.

N302899 March 13, 2019 CLA-2 OT:RR:NC:N4:410 CATEGORY: Country of Origin Ms. Paula Connelly Law Offices of Paula M. Connelly 100 Trade Center Suite 660 Woburn, MA 01801 RE: The country of origin determination of an LED light string from China. Dear Ms. Connelly: In your letter dated February 8, 2019, on behalf of your client Fourstar Group, Inc., you requested a country of origin determination ruling. The item concerned is referred to as to “Sound Activated Light String”. A sample was submitted with your ruling request. The Sound Activated Light String consists of an LED light string of approximately 195.5 inches long with 100 LED lamps and a battery compartment (control box) of approximately 3 inches wide x 2 inches deep x 1 inch high for three AA batteries (not included). The battery compartment (control box) contains a sound activated light string chip, a microphone and transistors, resistors, capacitors and a push-button switch for Light Show (responds to music), Steady On, Slow Pulse or Blinking. The sound activated light string chip allows the LED’s to flash in sync with the music. One merely turns the external music on, i.e., cell phone, stereo or similar, sets the sound activated light string into Light Show mode and the LED light string will pulse to the beat of the music. The Sound Activated Light String is comprised of the following components: LED Light String from China; Integrated Circuit designed and made in Taiwan; Printed Circuit Board (includes the IC and other components), and Plastic Battery Compartment (including compartment parts) from Vietnam. The production steps in Vietnam are as follows: PCB production – This consists of the Surface Mount Technology processing. All electrical components including the integrated circuit (Taiwanese origin), microphone, resistors and transistors are added to the board. Upon completion, the board is tested to ensure that it functions properly. Completed PCB is added into the Battery Compartment (control box). Battery Compartment (control box) – manufactured in a plastic injection molding process. Battery Compartment parts – Each battery contact is soldered into the Battery Compartment (control box). Light String - the Chinese origin string is cut to length and then wound to a coil. It is hot dipped in tin on one end and soldered to the printed circuit board assembly. The printed circuit board and LED string are then hot glued to the Battery Compartment (control box). Finished set testing. Testing includes powering up and testing sound activation function, testing the button function, and checking the string for any defective LED’s. Finished set packaging. Section 134.1(b), Customs Regulations (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 that you have provided, we find that the production process performed in Vietnam does not effect a substantial transformation. Although the light string was cut to length and attached to the Battery Compartment (control box) during production, it retains its essential identity and character as a light string. The production process does not create a new and different article of commerce with a distinct character and use that is not inherent in the component (light string) imported into Vietnam. The country of origin of the Sound Activated Light String imported into the U.S. will be China. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 CFR Part 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, contact National Import Specialist Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division