The country of origin of NanoCure

N345397 February 12, 2025 OT:RR:NC:N3:135 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee DrivePeabody, MA 01960 RE:  The country of origin of NanoCure Dear Ms. Murrin: In your letter dated January 24, 2025, you requested a country of origin ruling on the SprintRay NanoCure on behalf of SprintRay Inc. The SprintRay NanoCure is a post-curing device measuring 7.9 x 8 x 13.5 in. (W x D x H) that uses two wavelength (365 nm and 385 nm) LED lights to cure 3D printed dental appliances. It is designed for dental offices, enabling practitioners to have a curing device chairside. The device utilizes a combination of ultraviolet (UV) light and heat to transition 3D printed parts from their initial “green state,” where polymerization is incomplete, to a fully cured final state. The main components of the device are identified as a motherboard, a UV panel, a heater, and a fan. The NanoCure is designed and developed in the United States. Components from various countries are fully assembled in Mexico. Motherboard Production in Mexico: The Motherboard is equipped with an Android-based operating system and serves as the central processing unit, housing the curing logic for the device. It regulates the sequence and duration of UV light and heat application through communication with the driver board using the UART (Universal Asynchronous Receiver/Transmitter) communication protocol. The mother board functions as the “brains” of the NanoCure containing the logic and controls required to deliver the advanced synchronization of UV light, heat, and thermal management.  In Mexico, 257 electronic components from several countries are assembled to the motherboard using Surface Mount Technology (SMT). Then the motherboard undergoes stringent quality control processes including advanced X-ray and Automated Optical Inspection (AOI) technologies. Software and firmware, developed in the United States, are installed on the motherboard in Mexico, enabling the NanoCure to achieve full functionality. UV Panel Production in Mexico: The UV Panel functions as the primary curing source, initiating the photopolymerization process to advance the curing of the 3D printed parts. The UV panel consists of four side UV boards and two center UV boards with pillars for thermal management.  Each board is produced by assembling LEDs, temperature sensors, and connectors onto a bare PCB (printed circuit board) using SMT. Once assembled, the printed circuit board assembly (PCBA) undergoes stringent quality control processes. The lamp panel sub-assembly in Mexico: The side and center UV boards are assembled with Chinese-origin heat sinks, heat transfer plates (thermal pads), windshielding plates, screws, over-temperature protection switch (top over-temperature protection sensor), and lower lamp panel over-temperature protection switch (bottom over- temperature protection sensor) into a lamp panel sub-assembly. The fan sub-assembly in Mexico: A fan, a motherboard tower, nuts, and screws are sourced from China and assembled into a fan sub-assembly in Mexico. The final assembly processes for the NanoCure in Mexico: 79 components consisting of over 200 pieces including chassis, tray, shells, door, door handle, panels, heater, speaker, plates, antenna, screen, drawer slides, cables, nuts, screws, etc., mostly from China, are assembled by specialized technicians in Mexico. The processes include: front cover assembly, left and right mount slide installation, spacer assembly (light intensity small plate installation, heating pad installation, right and left limit switch installation, and temperature sensor installation), mid bulkhead mounting, light board assembly installation, debugging wiring, back cover assembly, motherboard tower assembly (Android motherboard installation; main board, ground wire installation; and main board tower mounting), wiring harness installation (LED driver board harness connection, speaker installation, Android motherboard harness connection, and installation of wiring harness), wire harness organization including foot mat installation and lower cover plate installation, and door frame installation. Each completed NanoCure undergoes calibration to optimize UV and heat intensity, light intensity testing, and thermal management testing in Mexico. 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). Based on the information presented, the NanoCure’s functionality is driven by its motherboard and UV LED boards, which are manufactured in Mexico. The production and assembly steps performed in Mexico in totality are complex and constitute a substantial transformation of the foreign origin components into a fully functional post-curing device. Accordingly, the country of origin of the NanoCure will be Mexico for purposes of applying trade remedies under Section 301. 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 Fei Chen at fei.chen@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division