Country of origin determination of an LED ceiling light

N307989 December 18, 2019 MAR-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Mr. Paul S. Anderson The Anderson Law Firm, LLC 111 Barclay Boulevard, Suite 206 Lincolnshire, IL 60069 RE: Country of origin determination of an LED ceiling light Dear Mr. Anderson: This is in response to your letter dated November 27, 2019, on behalf of your client Good Earth Lighting, Inc., requesting a country of origin determination for an LED ceiling light. The product at issue is an LED lighting fixture, which you refer to as the "Jordan FL 1217-14-Inch.” According to your letter, the key components of the product are the housing pan, retainer ring, glass diffuser, LED module, and lens PC barrier. All of the components are of Vietnamese origin except for the main integrated circuit (IC) board and polycarbonate raw materials from South Korea, ceramic resistor and capacitors from Malaysia, bridge diodes from Taiwan, and the glass outer envelope from China. The LED module is made in Vietnam with LEDs from China and capacitors, visitors, IC (integrated circuit), diodes and the PCB (Printed Circuit Board) from countries as specified above. None of these components are assembled until they are subjected to a technical SMT (surface mount technology) operation in Vietnam. The manufacturing process in Vietnam is described as follows: LED Module Assembly Process The process includes mounting the main integrated circuit, as well as various capacitors, visitors, fuse and diodes, etc. A group of 48 individual LED dies are bonded onto the module through a separate bonding process. Specifically, the bare printed circuit boards (PCBs) are fed into the start of an SMT (surface mount technology) production line. The solder paste is applied to the PCBs in the SMT production line. Solder paste is a form of solder used to make conductive joints of components onto the PCB. Solder paste is applied to the PCB by forcing the paste through a screen stencil to apply in a designated pattern where electrical components will be placed. In the next step of the process the PCBs with solder paste are fed into a high speed pick and place machine. The pick and place machine uses high speed robotic arms to remove or "pick" the electrical components from multiple reels and "place" them in specific locations on the PCBs where the solder paste has been pre-applied. After the PCBs have been populated with the required electrical components, they are fed into a reflow oven. The reflow oven slowly heats the board and solder paste to a specific temperature which will melt the solder paste and make the electrical connection between the electrical component and the PCB. Once reflow soldering is completed the PCBs containing soldered electrical components go through an automated x-ray inspection process to ensure the components are placed and soldered correctly. The populated PCBs are now ready for additional larger electrical components that will be added manually on the production line during final assembly. Metal Stamping Process The stamping process is to make the housing pan and retainer ring. It starts with purchasing steel in Vietnam that is already stamped into a round disc. For the housing pan, the in-house processing consists of 3 stamping tools lined up on 3 separate machines to progressively stamp the holes and form the metal. For the retainer ring, the in-house processing consists of 2 stamping tools lined up on 2 separate machines to progressively stamp the holes and form the metal. Painting Process This process consists of loading the housing pan and the retainer ring into pallet sized baskets for dipping in pre-treating chemical tanks to degrease, rinse and phosphate treat to prep for painting. The parts are then removed from the baskets and hung on a moving conveyor line that takes them through an oven to thoroughly dry them. After drying the parts go through the powder coating booth for the painting process. Injection Molding Process The process is to make the lens PC barrier, which is a polycarbonate plastic lens that is used to cover the LED Module. It is injection molded in house with a 2 cavity die. Polycarbonate raw material from South Korea is fed into the hopper, melted and fed through a screw-feed into a 2 cavity die. Pre-Assembly and Aging The housing pan, LED module and lens PC Barrier are screwed together to make the housing and module assembly. The assemblies are loaded onto carts equipped with electrical connection points and connected to power. The powered carts loaded with the housings and module assemblies are then connected to the main electrical supply at an elevated 130V. This will be tested for any initial failures or defects in the main electrical components. Final Assembly Process The final process is to assemble the LED module with the other components to create the finished light. The steps include, e.g., screwing the ground wire to the housing pan, soldering the wire leads to the LED module and the fuse to the LED module PCB, adding Epoxy glue to LED module wire leads, and securing the lens PC Barrier to the LED module and housing pan assembly with screws. After the initial testing of energizing the lamp, inspecting LEDs, checking electrical readings, testing dimming, and checking ground continuity, the assembly is loaded onto test carts for the burn-in test. Section 134.1(b), Customs Regulations (19 CFR § 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 process performed in Vietnam does constitute a substantial transformation of the imported materials into "products of" the Vietnam. In this case, the South Korea-origin PP raw materials are transformed into the lens PC barrier through injection molding, and similarly, the main integrated circuit board from South Korea, ceramic resistor and capacitors from Malaysia and bridge diodes from Taiwan are transformed into the LED module, which is a critical sub-assembly of the finished light fixture. In our view, the manufacturing process in Vietnam creates a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Vietnam. Therefore, the country of origin of the "Jordan FL 1217-14-inch" light will be Vietnam. 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