The country of origin of security lights

N323710 January 31, 2022 MAR-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Mr. Paul S. Anderson The Anderson Law Firm 111 Barclay Boulevard, Suite 206 Lincolnshire, IL 60069 RE: The country of origin of security lights Dear Mr. Anderson: This is in response to your letter dated January 14, 2022, on behalf of your client Good Earth Lighting, Inc., requesting a country of origin determination for security lights. The merchandise under consideration is identified as SE 1291 Security Light (the “SE 1291 light”). You present a manufacturing processing scenario for the country of origin determination of the SE 1291 lights.  Under the scenario, there are approximately 243 separate components shown in the bill of materials. The bill of materials lists the significant elements of the finished SE 1291 light, which include 1) Lamp Head module, 2) PIR (Passive InfraRed) Head module, and 3) Canopy module. For the Lamp Head module, the major subassembly is the LED PCBA (Printed Circuit Board Assembly) module; for the PIR Head module, the major subassembly is the PIR PCBA module; and for the Canopy module, the major subassembly is the Driver Power PCBA module. The first major subassembly is the LED PCBA module. It comprises numerous components that are sourced in China and imported into Vietnam, wherein all of these components are subjected to a Surface Mount Technology (SMT) procedure. The second major subassembly is the PIR PCBA module, which is the sensor portion of the finished 1291 light. Again, numerous components are imported from China into Vietnam, and all are subjected to an SMT procedure. The same is true of the third major subassembly, 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.    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. STM Process 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 fixture, these electrical components include the Main ICs, Resistors, Ceramic Capacitors, and LEDs. For the PIR module in the security light fixture, 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 fixture, these electrical components include the MOS, Capacitors, Socket, Fuse, Varistor, Resistors, Transistor, 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. Wave soldering process for insert components Wave soldering is a bulk soldering process used in the manufacture of printed circuit boards. The circuit board is passed over a pan of molten solder in which a pump produces an upwelling of solder that looks like a standing wave. As the circuit board makes contact with this wave, the components become soldered to the board. Wave soldering is used for both through-hole printed circuit assemblies and surface mount. In the latter case, the components are glued onto the surface of a printed circuit board by placement equipment, before being run through the molten solder wave. Wave soldering is mainly used in soldering of through hole components. Components such as the touch button, horizontal socket, varistor, thermistor and square fuse, electrolytic capacitor and connecting wire are inserted into the fitted board and placed into the wave soldering fixture. The primary objective of flux in the wave soldering process is to clean the components that are to be soldered, principally any oxide layers that may have formed. There are two types of flux, corrosive and noncorrosive. Noncorrosive flux requires pre-cleaning and is used when low acidity is required. Corrosive flux is quick and requires little pre-cleaning but has a higher acidity. Preheating helps accelerate the soldering process and prevent thermal shock. After wave soldering, it goes through tin-filling, QC appearance inspection and testing process, and finally can be added to other large electrical components in the production line during 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. ABS is a polymer of Acrylonitrile (Acrylonitrile), Butadiene (Butadiene) and styrene (Styrene), and has a certain surface hardness, toughness, impact resistance, surface gloss, chemical corrosion resistance, easy processing and other characteristics. ABS electroplating chemically etches Butadiene in ABS to make the surface of the product show some loose pores. A layer of conductor (such as copper) is then attached to make it conductive. ABS plating is a mixture of electro-less plating and electroplating. The process goes through degreasing, coarsening, neutralization, catalysis, de-gluing, 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 technical automated process, requiring sophisticated tooling. Set-up and maintenance of the tooling require engineering level support. The PIR arm is used to connect the PIR housing to the canopy. It is injection molded in-house 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. The control knobs, PIR reflector and some small seal silicone rings are also plastic injection molded. The PIR head module housing is a Polycarbonate plastic casing with Fresnel Lens that is used to hold the PIR PCBA module. It is injection molded in-house with a 2 cavity die and also using the insert-injection technology. 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 a simple object, such as a thread or rod, but in some cases, inserts can be as complex as a battery, motor or special component. In this case, the insert is the special component - Fresnel lens. It utilizes advanced quality molding machines that are explicitly designed for the insert injection molding process. The insert molding process necessitates extremely tight tolerances to ensure the proper formation of the plastic parts being created. Final Product Assembly Process The final assembly process requires various trained workers. The final assembly steps are as follows: PIR head module housing Fix the sensor head connection wires on the back shell of the sensor head with a wire plug. Apply Kraft silicone sealant to the outlet to secure as a strain relief and for waterproof. Clean the Fresnel lens & the PIR sensor using chemical solvent. Put on the waterproof ring in between the front and rear PIR housings and put the front and rear PIR housings together and secure. Install the rotary knob with waterproof ring. PIR housings are put on the matrix test jig to check the PIR before assembly to the canopy. It is then tested for the light perception day mode. The dark night mode testing occurs in the dark room in order that it is able to sense and trigger normally according to its detection angle and distance based on the specification. Light heads housing Secure the ground wire. Brush a layer of thermally conductive grease carefully & evenly on particular heat source components for heat dissipation. Install the LED PCBA in the light head housing carefully to avoid electrostatic shock and then affix the PCBA. Put the left and right sealing rings on both left and right lamp head housings respectively for waterproofing. Put the reflectors inside the light head housings. Put the left and right PC diffusers on the left and right light heads respectively in correct position tightly and pressing on the sealing rings properly to ensure the water-sealing in place. Secure the left and right PC diffusers. Connect the right and left upper arm shaft and clamping parts to left and right light head. Check the light head appearance and power using a test-jig for checking. Final product Check the appearance of the die-cast canopy then put the left lower arm on the left hole of the canopy adding the sealing ring. Put the right lower arm on the right hole of canopy adding the sealing ring. Connect the left light head putting the upper arm-end to the left lower arm-end left hole of the canopy, and fix the clamping waterproof ring. Connect the right light head with the arm then put the arm-end into right hole of the canopy. Secure the ground wires from left and right light heads together inside the canopy. Connect the wires from the driver module with the wires from the left and right light heads. Install the driver module into the canopy properly and secure. Connect the wires from the PIR module with the driver wires, then attach the PIR module housing to the Canopy tightly. Light up the semi-finished product for testing and test that the key switches work properly. Perform safety test on the lamp. Perform Dusk & Dawn test, test for lumen output, and test for waterproofing. Load goods and perform aging test. After the aging test is completed, all fixtures are inspected for any defects in the LEDs, unloaded from carts and placed on packaging assembly line. 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. 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, 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