The country of origin of OLED modules

N345329 February 19, 2025 OT:RR:NC:N2:208 CATEGORY: Origin Yoon-Sang Lee Kim & Chang 39, Sajik-ro 8-gil, Jongno-guSeoul 03170South Korea RE:  The country of origin of OLED modules Dear Mr. Lee: In your letter dated January 22, 2025, on behalf of Samsung Display Co., Ltd. you requested a country of origin ruling on organic light-emitting diode (OLED) modules. The merchandise under consideration is OLED modules for tablets and smartphones, models AMUA11DV01 and AMB686EP01, respectively.  These OLED display screen modules, which are designed to display information, are intermediate articles intended for use in the manufacturing of smartphones or tablets.  The components of the OLED Module are the OLED cell, which enables the OLED characteristics of the module, the polarizer (POL), the display driver integrated circuit (DDI), the flexible printed circuit assembly (FPCA), and the display cover window. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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). The OLED Cell, which is composed of self-illuminating organic materials for each model in question, is manufactured in Korea.  The OLED Cell Fabrication process involves the following steps: the thin film transistor (TFT) process, evaporation (EV) process, encapsulation (EN) process, and cell cutting process. During the first step in creating the OLED cell fabrication (FAB process), the TFTs are formed on a glass substrate by repeating patterning and deposition, thereby forming a TFT glass.  In the second step, the (EV process), produces/creates an EV glass from the TFT glass by depositing organic electroluminescent layers and cathodes on top of the glass substrate formed by the TFTs.  Both the TFT and EV processes determine the resolution, size, luminance, maximum scanning rate, color depth, etc., of the OLED modules.  The third step is the (EN process), in which the EV glass is bonded to another glass or covered by a thin film to prevent oxygen and moisture from penetrating the EV glass, thereby forming an EN glass.  Lastly, the cell is cut into the final products and tested.     In Vietnam, where the second step occurs, the assembly (ASSY) process occurs for both models.  These steps include assembling the OLED Module by attaching the POL, the DDI, the FPCA, and the Display Cover Window to the OLED Cell.  The PCBA, known as the Flexible Printed Circuit Assembly (“FPCA”) does not add any functionality to the display.  Based upon the facts presented, it is the opinion of this office that the Korean OLED panel, which is the key component of the OLED module, does not undergo a substantial transformation as a result of the processing that takes place in Vietnam.  The OLED panels have a predetermined end use when they are exported from Korea and retain that identity after the processing that takes place within Vietnam.  Accordingly, the country of origin of the finished OLED modules will be Korea for origin purposes at time of importation into the United States and as such, the Section 301 Trade remedy would not be applicable. 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