The country of origin of a 7-inch LCD monitor

N348702 May 22, 2025 OT:RR:NC:N2:208 CATEGORY: Origin Denise Wu Josefina Pan Pacific Limited 7F-6, No. 12, Fuxing 4th Road Qianzhen District, Kaohsiung City 806 Taiwan RE: The country of origin of a 7-inch LCD monitor Dear Ms. Wu: In your letter dated May 6, 2025, you requested a country of origin ruling on a 7-inch liquid crystal display (LCD) monitor. The merchandise under consideration is a 7-inch liquid crystal display (LCD) monitor, model number CM756S/H-L4, which is for use in a vehicle. The monitor is intended for car reversing applications. In China, the manufacturing process starts with production of the main board, control board, cables, and remote control. Then, the components are shipped to Taiwan. In Taiwan, the LCD panel, mount, housing, etc. are produced. The components from China and Taiwan are then assembled, tested and packaged in Taiwan. First, the mainboard, control board, and LCD panel are assembled into the mechanical housing (front and rear casings). Next, the cable is connected, and the connections and internal structure are fixed. Last, the stand, power module, and mechanical accessories are installed. When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, 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). Based on the facts presented, it is the opinion of this office that the origin of the monitor is the country in which the underlying main PCBA (main board) is produced. Accordingly, the Chinese main board imparts the prominent character of the device since it performs the primary and vital functions of the monitor, which is forming images for display. Further, in this case, the main board (PCBA) is made in China and the assembly process performed in Taiwan would not substantially transform the main board into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, we find that the country of origin of the subject monitor is China. 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