The country of origin of the LED Ceiling Panel Fixture

N344050 December 4, 2024 OT:RR:NC:N4:410 CATEGORY: Origin George Tuttle, III, Tuttle Law Offices 3950 Civic Center Drive, Suite 310San Rafael, CA 94903 RE:  The country of origin of the LED Ceiling Panel Fixture In your letter dated November 14, 2024, on behalf of Obert, Inc., Co., Ltd., you requested a country of origin ruling on an LED Panel Fixture for the purposes of China Section 301 remedies. The LED Ceiling Panel Fixture consists of a cold rolled steel housing and an aluminum frame, within which are 84 individual LED diode mounted on six parallel light strips wired to a low voltage (12-24V), direct-current driver, and covered by a clear polystyrene light diffusion panel. The housing and frame, diffusion panel, driver, DC terminal are of Chinese origin. It is stated that this ruling request follows the same manufacturing steps and components as ruling N342388, dated September 24, 2024, except that the LED driver board is produced in China. The LED driver production in China involves a three-step process, i.e., SMT (surface mount technology), DIP (dual inline packaging) production and final driver assembly. The LED driver board will be incorporated into the production line by connecting the LED driver terminal wire to the driver and mounting it into the driver box in Mexico. The proposed manufacturing process of the LED Panel Fixture in Mexico will comprise the light source production and main production. Your submitted documents indicate that each of these production steps consist of many sub-steps of operations and the use of sophisticated equipment. The manufacturing process scenario presented in your submission is summarized as follows: The LED light source production line generates the LED light strips used to illuminate the LED Panel Fixture. Each light strip is composed of an aluminum printed circuit board, PCB, to enhance heat dissipation, multiple LED diodes (3500K, 5000K, or both) with lenses, and resistors. The unpopulated aluminum substrate sheets (later cut into individual strips) are placed onto the loading machine to begin the light source production line. Numerous electronic components will be placed onto the PCB sheet to produce the LED light source strip via SMT process. The operations include paint solder paste application, surface mounting components, reflow soldering, solid adhesive dispensing, lenses addition, and light up testing. In the main production line, the process starts with the robotic arm placing the housing into position, then it goes through operations of silicon dispensing, light source sheet slitting, LED driver terminal formation, light strip adhesion, frame and diffusion panel affixing, hook installation, driver box and LED driver installation, and lighting testing. When determining the country of origin for purposes of applying current trade remedies under Section 301 (insert Section 301, Section 201, or Section 232, as appropriate), 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). We find that the operation of assembling the Chinese origin components and the Mexican origin PCBAs to make the finished LED Ceiling Panel Fixture in Mexico results in a substantial transformation. The SMT and wave soldering processes, the making of the light source and PCBA etc., along with other assembly activities are sufficiently “complex and meaningful” operations. The assembly of the individual components to produce the finished light fixtures in Mexico does create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Mexico. Therefore, the country of origin of the LED Panel Fixture is Mexico, China Section 301 remedies do not apply. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division