The country of origin of an LED tub light

N351143 August 4, 2025 OT:RR:NC:N4:410 CATEGORY: Country of Origin Long Chen Thai Jiuzhou Electron Co. Ltd. 88/152 Moo 15 Bangsaotong Sub-District Bangsaotong 10540 Thailand RE: The country of origin of an LED tub light Dear Mr. Chen: In your letter dated July 9, 2025, you requested a country of origin ruling on a tub light. The product under consideration is identified as the Tub Light, Item 308D1661P001 (the “tub light”). The images provided in the Bill of Materials (BOM) indicate that the tub light has a printed circuit board assembly (PCBA), lens, lamp base, PVC sealing, an O-ring, and a harness. The tub light is to be used inside of a dryer or washing machine. The light will go on/off when the door is open/closed. You present two manufacturing process scenarios, in which the factory in Thailand produces the PCBA (light source) and the lens (only in Scenario 2 as presented below), and then assembles the components of both Chinese-origin and Thai-origin to manufacture the finished tub lights. Scenario 1 The harness, plastic base, PVC sealing, and O-ring are of Chinese origin. The PCBA is made in Thailand via surface mount technology (SMT) where the printed circuit board (PCB) is populated with an LED from South Korea along with other electronic components. The lens is made in China through plastic injection molding with the US-origin resin PCTG (Poly Cyclohexylenedimethylene Terephthalate Glycol). Scenario 2 The difference between Scenario 1 and Scenario 2 is the production of the lens. In Scenario 2, the lens is made in Thailand where injection molding is done to US-origin resin PCTG. The rest of the manufacturing processes (including the final assembly) will be the same in Scenarios 1 and 2. You summarize the assembly process in Thailand as follows: Assembling the lens with the O-ring Assembling the PCBA to the lamp base Assembling the harness (connecting the wires with the plug and the light head) Sealing Testing When determining the country of origin, 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). To determine whether a substantial transformation occurs when components are assembled into completed products, all factors such as the components used to create the product and the manufacturing processes these components undergo are considered to determine whether a product with a new name, character, and use has been produced. No one factor is decisive, and assembly/manufacturing operations that are minimal will generally not result in a substantial transformation. Based on the facts presented, it is the opinion of this office that the PCBA (light source) is fabricated in Thailand. It is the most important or critical component in the subject LED tub light, which also imparts the character of the LED tub light. The LED chip-mounting operation and SMT process with other assembly operations performed in Thailand are complex and meaningful, thus, the substantial transformation has occurred. As such, country of origin of the LED tub light is Thailand for purposes of current trade remedies. 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, (for) James Forkan Acting Director National Commodity Specialist Division