The country of origin determination of the LED stage light

N306277 October 1, 2019 CLA-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Mr. Kunchih Wang Acmetec Holdings Limited Taiwan Branch No. 22 Songbai Road, Linkou District New Taipei City 24451 Taiwan RE: The country of origin determination of the LED stage light Dear Mr. Wang: This is in response to your letter dated September 17, 2019, requesting a country of origin determination for the LED “Moonflower Effect Lighting." According to the information that you have provided in your letter and on the product websites, the “Moonflower Effect Lighting" is a stage light consisting of a housing, LED lamps, a lens, a hanger and a remote control. The Bill of Materials shows that major components are from China. They include: a PCB (printed circuit board) with LED chips, a PCB for function display, a PCB for signal, a PCB for infrared receiver, a main PCB with control chips, a power supply, an IEC connector, a power cable, a Fresnel lens, an infrared transmitter, a hanger and various plates and panels, etc. The Taiwanese origin components are the firmware (software for lighting control), fuses, wires, screws and washers, adhesive stickers, packaging materials, etc. It is stated that the assembly process in Taiwan consists of five phases as follows. Phase I: Connect/solder the lead wires, ground wires, microphone, power supply and power cable connector to make subassemblies. Phase II: Assemble the mainboard, LED board, function display board, Fresnel lens, metal covers and other components by screwing, soldering, inserting subassemblies, fastening connectors, etc. Phase III: Install the firmware and perform the cosmetic inspection, high voltage test and function test. Phase IV: Conduct the adjusting and aging test to adjust the product’s structure and lens position, etc., followed by an all-function test program in a console for 24 hours. Phase V: Pack the product in a plastic bag for shipping 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 submitted, we find that the assembly operations performed in Taiwan do not substantially transform the imported components and materials into Taiwanese products. The assembly process in Taiwan, i.e., connecting/soldering wires and assembling the various components including installing the firmware, to produce the finished stage light does not create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Taiwan. The major components, which are imported from China, retain their essential identity and character in the finished product of the stage light. Therefore, we are of the opinion that the country of origin for the “Moonflower Effect Lighting" will be China. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 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