The country of origin of thin-film transistor (TFT) liquid crystal display (LCD) modules

N343835 December 4, 2024 OT:RR:NC:N2:208 CATEGORY: Origin Richard Suh Toshiba Logistics America, Inc. 501 Burning Tree RdFullerton, CA  92833 RE:  The country of origin of thin-film transistor (TFT) liquid crystal display (LCD) modules Dear Mr. Suh: In your letter dated November 5, 2024, on behalf of JDI Display America Inc., you requested a country of origin ruling on thin-film transistor (TFT) liquid crystal display (LCD) modules The merchandise under consideration is thin-film transistor (TFT) liquid crystal display (LCD) modules, part numbers LPM123G351C, LPM124G358C, LPM124G358D, and LPM124G358F, which are specifically designed for integration into automotive systems for head-up displays (HUDs).   In Japan, the manufacturing process starts with a glass substrate.  Multiple steps are done in CVD (chemical vapor deposition) machines to create a TFT (thin- film transistor) array structure on the substrate, which is done for every subpixel.  Next, a color filter (black matrix, red, green, and blue) is completed on a matching and separate glass substrate, for every subpixel.  Third, the LCD panel is filled by a one drop fill (ODF) process that is applied to the entire TFT array substrate, and the liquid crystal material is compressed between the TFT array side when the color filter glass substrate is added and aligned on top.  Then, it is shipped to China. In China, the substrate is cut into “chips” (individual LCD panels).  After that, the module is fully assembled by affixing the driver integrated circuits (ICs), polarizers, and flexible printed circuit(s) (FPCs) to the LCD cell (the "chip"), and then adding the backlight, frame, etc.  Lastly, the finished LCD module goes through quality testing. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018.  The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing.  See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982).  This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Accordingly, it is our opinion that the completed TFT-LCD cells, regardless of where they are cut to size, are the dominant component that provides the character of the finished flat panel display modules.  The complex manufacturing process performed in Japan renders the end-use of the cells predetermined, as they cannot be used for any other purpose than a display.  Further, the assembly processes performed in China would not substantially transform the cells into new and different articles of commerce with a name, character, and use distinct from that of the exported good.  Therefore, based upon the facts presented, the country of origin of the subject TFT-LCD modules is Japan. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request.  This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1).  This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect.  In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 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, please contact National Import Specialist Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division