The country of origin of an LED emergency light

N345899 March 6, 2025 OT:RR:NC:N4:410 CATEGORY: Country of Origin Deanna Gresens Transmodal Corporation 545 Island RoadRamsey, NJ 07446 RE:  The country of origin of an LED emergency light Dear Ms. Gresens: In your letter dated February 12, 2025, on behalf of Hexmodal Technologies, you requested a country of origin ruling on an LED emergency light for purposes of applying current trade remedies under Section 301. Based on the description and pictorial illustration in your submission, the LED emergency light consists of a plastic back plate, batteries, a main printed circuit board assembly (PCBA), a plastic housing (to which two LED lamps or light heads are attached), two plastic lamp housings, two LED PBCAs (one for each lamp), a reflector and two lenses. The LED PBCAs are populated with LEDs forming the LED light boards (light source). All of the components and materials are from China except for the main PCBA and the LED light boards (light source) which are made in India. The PCBAs are manufactured in India, which starts with the designing and production of the PCBs. The PCBs are then populated with the imported electronic components via the SMT (surface mount technology) process to make the PCBAs. The SMT process involves mounting the various electronic components, e.g., capacitors, varistors, fuses, diodes, etc., which goes through the steps of first surface-mount devices (SMD), through hole components manual soldering, SMD soldering, and through hole (TH) component soldering. In particular, the PCBAs for the light heads are populated with the LEDs to make the LED light boards (light source) in India during the process. The final assemblies include assembling all the imported components together with the PCBAs (including the LED light boards), firmware loading and testing to make the finished emergency lights. 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). We note that the emergency light and the manufacturing process scenario are similar to those in ruling N344188, dated December 9, 2024. Accordingly, we find that, although a significant number of the parts or components are made in China, the PBCAs (including light source) are the most important and critical components in the subject LED emergency light. The assembly operations, especially the SMT process, performed in India are complex and meaningful. The substantial transformation occurs. Therefore, the country of origin of the LED emergency light is India, 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