The country of origin of security lights

N323210 January 5, 2022 MAR-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Mr. Paul S. Anderson The Anderson Law Firm, Suite 206 111 Barclay Boulevard Lincolnshire, IL 60069 RE: The country of origin of security lights Dear Mr. Anderson: This is in response to your letter dated December 13, 2021, on behalf of your client Good Earth Lighting, Inc., requesting a country of origin determination for a security light. The merchandise under consideration is identified as SE 1249 Hyperbright Security Light (the “Security Light”). You present a manufacturing processing scenario for the country of origin determination of the Security Lights.  Under the scenario, there are approximately 443 separate components shown in the bill of materials, but some, particularly the smaller components, are duplicative as to name and function. The core components are components for the LED PCBA (bare board along with unassembled resistors, capacitors, LEDs, diodes, transistors, MOS and IC); components for the PIR PCBA Module; components for the Driver Power PCBA Module; die-cast lamp head; diffuser lens; driver housing and PIR housing. These individual and unassembled components are imported from China. The rotatable shaft/connection arms are sourced and produced in Vietnam. The other components are generally adjunct, minor components such as wire, bolts, washers, etc.   There are three major module sub-assemblies in the finished Security Light. The first sub-assembly is an LED module which is referred to as "LED PCBA Module". Numerous discrete components comprising this module are sourced in China and imported into Vietnam, wherein all of these components are subjected to a Surface Mount Technology (SMT) procedure.   The second module is a PIR module referred to as the "PIR PCBA Module" which is the sensor portion of the finished Security Light. Similarly, numerous discrete components are imported from China into Vietnam, and all are subjected to an SMT procedure in Vietnam.   The same is true of the third module which is the driver module and referred to as the "Driver Power PCBA Module".  Numerous discrete parts are imported from China into Vietnam and a complex SMT procedure is employed resulting in a finished Driver Power PCBA module of Vietnamese origin.   Aside from manufacture of the three subassemblies as noted, several other important processes are employed in Vietnam. A plastic electroplating process is utilized in connection with the PIR Reflector.  Also, a silicone molding process is utilized with various components such as the PIR housing and control knob.   An injection molding process is used to produce the lens PC barrier and the connector arms.  The lens PC barrier is a polycarbonate plastic lens used to cover the LED module. Also subjected to an injection molding process are the rotatable shaft arms and levers.   Specifically, the manufacturing process in Vietnam is further described as follows: LED Module, PIR Module and Driver Module Assembly Process LED Module, PIR Module and Driver Module utilize SMT assembly which is a sophisticated technical process requiring highly skilled workers, a clean room environment and high cost machinery. Bare Printed Circuit Boards (PCB’s) are fed into the start of an SMT production line. The first step in the process is to apply a solder paste to the PCB. 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 PCB with solder paste is 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 PCB where the solder paste has been pre-applied. For the LED module in the Security Light these electrical components include the Main ICs, LEDs, zenor diodes, MOSFET, resistors, ceramic capacitors, and transistors. For the PIR module in the Security Light these electrical components include the connector socket, capacitors, LDO IC, resistors, main IC, LED, PIR sensor, CDS, and varistor. For the Driver module in the Security Light these electrical components include the varistor, transistor, main IC, resistors, ceramic capacitors, diodes, zenor diode and rectifier. All of the electrical components used in these three modules are imported from China. After the PCB is populated with the required electrical components, it is 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 components and the PCB. Once reflow soldering is completed the PCB containing soldered electrical components goes through an automated x-ray and optical inspection process to ensure the components are placed and soldered correctly. The populated PCB is then ready for additional larger electrical components that will be added manually on the production line during final assembly. Electroplating Process Plastic electroplating is a process in which a conductive film is first obtained on the surface of the plastic by a certain processing method (usually Electroless Plating) and then thickened by electroplating. The PIR reflector for the security light base material is ABS material. The ABS is a polymer of Acrylonitrile, Butadiene, and Styrene. It has a certain surface hardness, toughness, impact resistance, surface gloss, and has chemical corrosion resistance, easy processing, and other characteristics. ABS electroplating is chemically etched in ABS to make the surface of the product show some loose pores, and then attach a layer of conductor (such as copper) to make it conductive, and refer to the way of metal electroplating to electroplate a layer of metal film on its surface. Therefore, ABS plating is a mixture of electroless plating and electroplating. The process goes through degreasing, coarsening, neutralization, catalysis, degluing, covering chemical nickel layer, covering bright copper layer, plating semi-bright nickel layer, plating chromium layer, and finally drying and packaging. Injection Molding Process Injection molding is a highly technical process, fairly automated, and requires sophisticated tooling. Set-up and maintenance of the tooling requires engineering level support. The operators are moderately skilled and trained in machine operation and part inspection. The lens, connection arm section, and PIR housing are plastic injected parts. The connection arm is a polycarbonate plastic that is used to connect the lamp to the canopy. It is injection molded with a 2 cavity die. Polycarbonate raw material is fed into the hopper, melted and fed through a screw feed into a 2 cavity die with a 60 second cycle time. When parts are ejected from the machine they are inspected, cut away from the support ribs and stacked in a transport container ready for use in final assembly. The control knobs, PIR reflector and some small seal silicone rings are also produced with a plastic injection molding process. When parts are ejected from the machine they are inspected, cut away from the support ribs and stacked in a transport container ready for use in final assembly. The rotatable shaft arm is a polycarbonate plastic that has a rotary feature used to connect the PIR housing and metal stamp housing (die-cast lamp head), in which the adjustable lever is used with insert injection molding process. It is injection molded in the Vietnamese factory with a 2 cavity die and also using the insert-injection technology. Polycarbonate raw material is fed into the hopper, melted and fed through a screw feed into a 2 cavity die with a 60 second cycle time. Insert injection molding is the process of molding or forming plastic parts around other, non- plastic parts, or inserts. The inserted component is most commonly an object, such as a thread or rod, but in some cases, inserts can be as complex as a battery, motor, or special component. When parts are ejected from the machine they are inspected, cut away from the support ribs and stacked in a transport container ready for use in final assembly. Final Product Assembly Process The entire fixture assembly process requires a mixture of high skilled and regular workers. All workers are trained in their positions. There is also overall line supervision and Quality Control oversight. For the assembly process a moving conveyor belt is used between assembly stations. All parts are brought in bulk to the assembly line and staged for assembly. The final assembly steps include the PIR sensor module housing assembling and the final product assembling. The PIR housings are put on the matrix test jig to check the PIR before assembly to the canopy. It is subjected to a test for the light perception day mode. It is then tested for the dark night mode in the dark room so that it can sense and trigger normally according to its detection angle and distance based on the specification. The final product assembly includes installing the silicone buttons in the button position of the main body of the lamp, affixing the drive power fixing seat, putting the LED PCBA in the designated position of the lamp and soldering the wire leads to LED PCBA; affixing the LED PCB with screws, then adding the cooling glue carefully on particular heat source components for heat dissipation, putting the driver module into the driver power fixing seat and fixing it; secure the sensor head on the main body of the lamp by 2 screws, then passing the sensor head connection wires and the power wires on the drive power board through the middle hole of the lamp body and tie them together; soldering the connecting wire leads of the driving power board and the lamp board to the lamp board pad according to the color correspondence and finally, lighting up the semi-finished product for testing and test that the key switches to ensure no problem. After the testing, the process goes on to install the sealing ring, reflector, lens diffuser and then fix the light cover, secure the ground wire, add the PIR sensor to the die-cast and route the wires, add sheath sleeves to the back of the die-cast, use the silicone sealant on the outlet of the main body of the lamp for waterproofing, and install the rear shell cover. The comprehensive final testing and inspection follow, which include testing on the lamp and PIR sensor Dusk & Dawn tests, environmental test (change of temperature and humidity) in the chamber, as well as IP65 waterproof check, Acceptable Quality Levels (AQL) sample size for temperature check on LED and driver, lumen output and other lighting parameters measurement, and the aging test, in which, the functions of the sensor, knobs timer, and CCT & dimming are tested, and the light will be turned on at special ambient environment for 4-hours aging. 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”. In order to determine whether a substantial transformation occurs when components of various origins are assembled into completed products, CBP considers the totality of the circumstances and makes such determinations on a case-by-case basis. The country of origin of the item’s components, extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, and use are primary considerations in such cases. Additionally, factors such as the resources expended on product design and development, the extent and nature of post-assembly inspection and testing procedures, and worker skill required during the actual manufacturing process will be considered when determining whether a substantial transformation has occurred. No one factor is determinative. Based on the information submitted, the components and parts are imported into Vietnam where they are manufactured into different subassemblies, which are ultimately assembled into the subject Security Lights. We find that the processing performed in Vietnam with respect to the Security Lights in the scenario does constitute a substantial transformation of the imported components and parts into "products of" Vietnam. The manufacturing process in Vietnam transforms the non-originating components and parts to produce the finished Security Lights. It 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 "product of" requirement has been satisfied. It is of the opinion of this office that the country of origin for the Security Lights 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