The country of origin of an LED Mini Light Bar

N348066 May 8, 2025 OT:RR:NC:N2:201 CATEGORY: Origin David Robeson Mohawk Global 123 Air Cargo Road Syracuse, NY 13212 RE: The country of origin of an LED Mini Light Bar Dear Mr. Robeson: In your letter dated April 21, 2025, you requested a country of origin ruling on a LED Mini Light Bar assembled in China from Vietnamese and Chinese components on behalf of your client, Buyers Products, located in Mentor, Ohio. In your email to this office, dated April 29, 2025, you indicated that you are seeking this country-of-origin determination for Section 301 Trade Remedy purposes. The item under consideration has been identified as a 15 Inch Octagonal LED Mini Light Bar, Buyers Part Number 8891062. You state in your request that this LED light bar is used on the Snowplow Truck, Work Truck, Pickup Trucks, and Trailers. It is designed to be placed outside on top of a work truck’s cab as a signaling device to other vehicles/pedestrians to proceed with caution around this vehicle. The LED light bar consists of a lens, reflector, printed circuit board assembly (PCBA) light board containing 68 LEDS, a sealing ring, plastic housing/frames, as well as a magnetic base. The light bar also includes a 15 ft power cord with an accessory power plug with an on/off switch. The magnetic base allows the light bar to attach to the cab, or it can be permanently attached with the mounting feet. The amber light comes with a SAE J845 Class 1 rating and the item features ten adjustable flash patterns. The terms PCB (Printed Circuit Board) and PCBA (Printed Circuit Board Assembly) are often used interchangeably, but they refer to different stages of production. While a PCB refers to the bare board that provides a foundation for electronic circuits, a PCBA is the complete assembly where components are soldered onto the PCB to create a functional product. The PCBA light boards are manufactured in Vietnam via Surface Mount Technology process. The PCBA is populated with an IC chip, as well as various fuses, diodes, capacitors, varistors, etc. The process involves: Screen printing Glue dispensing Component placement Reflow soldering Cleaning Final inspection Once completed, the PCBA light boards are packaged and shipped to China as a completed unit. In China, the PCBA light boards are physically assembled with the other components (all of Chinese origin). The components include: Lens Reflector Magnetic housing 15-foot power cord 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). In your request you indicate that it is your opinion the country of origin is Vietnam as the PCBA represents the “character” of the item. We agree. Although some of the components, such as the lens and refractors, are produced in China and the manufacturing process occurs in China, the LED PCBA is the single most important and critical component. The assembly in China is, in our opinion, a simple assembly that involves manually inserting the PCBA board in the housing and snapping the housing onto the magnetic base. It possesses the predetermined end-use for the making of the LED mini light bar. The use of the article has already been pre-determined upon importation from Vietnam to China. The assembly operations performed in China do not substantially transform these Vietnamese originating components into Chinese products. The assembly in China of the additional individual components to produce the finished LED mini light bar does not create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into China. The key component of the LED mini light bar, e.g., the LED PCBA, does not lose its individual identity as a result of the assembly process in China. Therefore, the country of origin of the LED Mini Light Bar is Vietnam. As the country of origin of the subject item is Vietnam, the Section 301 Trade Remedy duties are not applicable to the LED Mini Light Bar under consideration. 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 Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division