The country of origin of a carrier plate assembly for red dot sights

N350680 July 15, 2025 OT:RR:NC:N2:209 CATEGORY: Origin Scott Angus Leupold & Stevens, Inc 14400 NW Greenbrier Parkway Beaverton, OR 97006 RE: The country of origin of a carrier plate assembly for red dot sights Dear Mr. Angus: In your letter dated June 26, 2025, you requested a country of origin ruling. The merchandise under consideration is described as a carrier plate assembly, Part number 173804, which is a component that goes into a finished red dot sight. The component consists of a carrier plate, which is a metal piece specifically designed to fit inside a red dot sight housing and a flexible ribbon cable with LED. The LED light sits on top of the carrier plate, which will eventually project a beam of red light onto a reflective lens to create an illuminated aiming point in the form of a red dot. The carrier plate is manufactured in Vietnam and the flexible ribbon cable with LED light is produced in Taiwan. Next, the two components are shipped to China for final assembly. In China, the two components are bonded together to ensure the LED light is precisely positioned on top of the carrier plate. Then the finished carrier plate assembly will be shipped to the United States for final assembly into a complete red dot sight. 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 information provided, it is the opinion of this office that the character of the finished carrier plate assembly is imparted by the flexible ribbon cable with LED of Taiwanese origin, which would be considered the dominant component. The carrier plate and flexible ribbon cable with LED are merely glued together in China and does not affect a substantial transformation. The flexible ribbon cable with LED retains its own identity with a predetermined end use. Therefore, since a substantial transformation does not occur as a result of the Chinese processing, the country of origin for the finished carrier plate assembly will be 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, James Forkan Acting Director National Commodity Specialist Division