The country of origin determination of an LED light

N307490 December 5, 2019 CLA-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Ms. Ada Grace Meteor Illumination Technologies Inc. 1300 John Reed Ct., Unit B City of Industry, CA 91745 RE: The country of origin determination of an LED light Dear Ms. Grace: This is in response to your ruling request received on December 8, 2019, requesting a country of origin determination for an LED light that you refer to as the Wiz LED Fixture. According to the information that you have provided in your letter and subsequent e-mails, the Wiz LED Fixture is an LED lighting fixture consisting of approximately 20 components. Major components include a housing, LED chips, a Metal Core Printed Circuit Board (MCPCB), drivers, a lens, a heatsink, a glass cover, a power supply box and plastic/rubber gaskets. The Bill of Materials shows that all of the components are from Taiwan except that the LED chips are from Japan, the drivers are from Mexico and the surge protector is from China. The major manufacture process in Taiwan includes the making of the light head and the power supply box. The making of the light head starts with the assembly of the LED board by attaching the Japanese origin LED chips to the MCPCB. You describe that this assembly process is comprised of three specific steps as follows: Solder Paste Printing - Solder paste is applied to the appropriate pads on the MCPCB using a stencil and squeegees in the solder paste printer machine. Component Placement - Once the printed MCPCB is confirmed to have the correct amount of solder paste applied, each LED is picked from its packaging using a vacuum that is checked by the vision system and placed in the programed location at high speed. Reflow Soldering - After all LED placements are checked to have been correctly placed in the MCPCB assembly, they are moved into the reflow soldering machine where all the electrical solder connections are formed between the LED and MCPCB by heating the assembly to a sufficient temperature. The LED board, made through the above three processes, is then assembled with other components (such as the glass cover, heatsink, lens etc.,) by screwing, soldering, gluing and fastening to make the LED light head. The assembly of the power supply box involves screwing, wiring and soldering the Chinese origin surge protector, the Mexican origin drivers and other components into the metal power supply box. An 8-hour burn-in test is performed before packaging and packing for shipment. 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 majority of the components in the Wiz LED Fixture are made in Taiwan and the assembly operations performed in Taiwan substantially transform the imported components, i.e., the LED chips from Japan, the driver from Mexico and the surge protector from China, into the Taiwanese product. The manufacture process in Taiwan, e.g., the making of the LED board and assembling the various components to produce the finished light fixture, creates a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Taiwan. Therefore, we are of the opinion that the country of origin for the Wiz LED Fixture will be Taiwan. 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