The country of origin of Thin Film Transistor Modules

N345496 February 19, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Helen XiaoErnst & Young LLP155 North Wacker DriveChicago, IL 60606 RE:  The country of origin of Thin Film Transistor Modules Dear Ms. Xiao: In your letter dated January 29, 2025, on behalf of your client, AUO Display Plus, you requested a country of origin ruling on a Thin Film Transistor (TFT) sensor module. The item under consideration is described as a Thin Film Transistor Sensor Module, which is a device designed to detect or sense light of extremely short wavelength and convert electrical (analog) signals into digital signals. The module measures roughly 269.2mm by 362.1mm by 15.5mm. These modules are designed for use in a variety of applications, including medical imaging, security screening, industrial inspection, astronomy, and archaeology. As an example, TFT Sensor Modules can be integrated with X-ray machines to form various X-ray systems. Specifically, a testing object is placed between the X-ray tube and the TFT Sensor Module. When the X-ray tube emits X-rays that pass through the testing object, the X-rays expose the Cesium Iodide (CsI) scintillator, which then converts the X-rays into visible light. The visible light is absorbed by the photodiode, generating an electrical signal that is stored in the pixel. The electrical signal generated by the photodiode is an analog signal that represents physical measurements. The system board provides voltage to drive the gate Chip-On-Film (COF) and trigger the TFT channel to turn on, allowing the Readout COF to read the electrical (analog) signal from each pixel. Each pixel generates a different amount of electrical (analog) signal based on the light it absorbs, resulting in varying electron charges on each pixel. Finally, the Driver COF converts the electrical (analog) signal into a digital signal. This digital signal, which is the discrete signal resulting from the analog-to-digital conversion, can be processed by digital systems. The signal is stored on the system board and transmitted to a computer. Regarding the origin of the TFT Sensor Module, under the current production arrangement, critical components of the TFT Sensor Module will be produced primarily in Taiwan, with some processing taking place in China. The core parts of the TFT Sensor Module will be manufactured under the first two processing steps in Taiwan. First, the TFT-Photodiode Sensor Process, and second, the Driver COF and Readout COF Bonding Process. The third step occurs in China where a processing step to deposit a layer of chemical and aluminum will take place. The fourth step is back in Taiwan and includes the system board and component assembly process. Finally, the finished articles are packaged and shipped from Taiwan. Step one (the TFT Photodiode Sensor Process) manufactures the TFT-photodiode sensors by integrating TFTs with photodiodes, enabling the sensor to efficiently detect light and convert it into electrical (analog) signals. The process starts with cleaning the substrate followed by the deposition of thin films. In this step, thin film layers, including oxides, nitrites, metals, or semiconductor materials are deposited onto the cleaned substrate. These films are crucial for constructing the gate, source, and drain regions of the TFTs, as well as the photosensitive layer of the photodiodes. Next, the photolithography process patterns the deposited thin films according to a design layout. The process involves applying a uniform layer of photoresist over the thin films, exposing the photoresist to ultraviolet (UV) light through a mask, which defines the pattern, and developing the exposed photoresist to remove the areas that were exposed to UV light (for positive photoresist), revealing the underlying thin film in those areas. Then a dry etching and wet etching process is performed followed by the stripping process, in which the remaining photoresist is completely removed. Step two (Driver COF and Readout COF Bonding Process) involves the assembly and connection of components in the manufacturing of TFT-photodiode sensors, focusing on the use of COF technology and Anisotropic Conductive Film (ACF) to create reliable electrical systems. The COF system is comprised of a Driver and a Readout COF. The Driver COF signals to the TFT-sensor panels controlling timing and voltage levels to the sensor panels. After the signals are received, the Readout COF converts the electrical (analog) signals into digital signals. At the end of step two, the semi-finished TFT Sensor Module is capable of detecting light and converting it into electrical (analog) signals, which the Readout COF then converts into digital signals. The first step is to utilize a specialized machine that punches COF from a coil and sends a single COF to the subsequent equipment for further processing. Next, the COF and panel leads are connected with adhesive that provides electrical conductivity in the vertical direction (between the COF or panel lead and the component it is attached to) while being insulated in the horizontal direction. Finally, the bonding process attaches the COF to panel pad leads. After the COF bonding process, Tuffy adhesive is applied on top of the COF as an additional protective layer. Step three (Cesium Iodide Scintillator Deposition and Backplane Lamination Process) is performed in China on the semi-finished TFT Sensor Module. In this step, Cesium Iodide (CsI) is disposed onto the semi-finished TFT Sensor Module, followed by the application of an aluminum film for protection. CsI is a photosensitive material that aids in the conversion of X-ray into visible light. The CsI acts as a conversion layer with iodine atoms which absorb X-rays and transform them into visible light photons. The CsI enhances the ability of the TFT Sensor Module to target electrical (analog) signals by giving it the ability to convert invisible X-rays into visible light. During the CsI evaporation the CsI material is placed into a machine with a low-pressure environment and gradually heated to cause evaporation. This is a part of the physical vapor deposition (PVD) process, where the material is vaporized and then condenses onto the TFT-photodiode sensor. After the CsI thin film has been deposited, an aluminum film is applied to the surface as a protective layer. Following the CsI deposition process, the product is laminated with a backplane. The backplane provides mechanical support for the product, ensuring its structural integrity. The fourth and final process occurs in Taiwan and involves the assembly and finalization of the electronic system, focusing on securing the Printed Circuit Board Assembly (PCBA or System Board), connecting boards using Flexible Flat Cables (FFC), applying thermal pads for heat management, installing covers for mechanical support, and conducting a final function test. The main function of the System Board, whether the model consists of three boards, or a 3-in-1 board, is to provide power and integrate panel digital signals. A three-board System Board is made up of three boards: the read, gate, and core board. The gate board directs power to the TFT-sensor and controls the digital circuits. The signals from the TFT-board are acquired by the read board and transmit the signal to the core board. The core board acts as the main processing unit, providing power to the system while providing the digital signal buffer and packing functions. The completed TFT Sensor Module is then packaged and shipped. 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 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). Regarding the country of origin of the subject TFT Sensor Module, based on the information provided, it is our opinion that the TFT-photodiode sensors manufactured in Taiwan imparts the essence of the finished module. At the end of step two, the semi-finished TFT Sensor Module is capable of detecting light and converting it into electrical (analog) signals, which the Readout COF then converts into digital signals. At this point, the end-use of the module is predetermined, as it could not be used for any other purpose than that of a light sensor module. Further, the additional processing performed in China simply enhances the capabilities of the module and does not substantially transform the module into a new and different article of commerce with a name, character, and use distinct from that of the exported good. Therefore, based upon the facts presented with this case, it is the opinion of this office that the country of origin of the TFT Sensor Module is Taiwan.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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division