The country of origin of a laser measurement tool

N351962 August 26, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a laser measurement tool Dear Mr. Jin: In your letter dated August 4, 2025, you requested a country of origin ruling on a laser measurement tool. Descriptive literature was provided for our review. The item under consideration is described as a laser measurement tool, which is a battery-operated electronic device used to provide various measurement readings. It works by emitting a laser pulse and calculating the distance based on the time it takes for the beam to return to the device after reflecting off a target. This “time of flight” measurement is highly accurate, especially for shorter and medium-range distances. The measurement range is 1.15 inches to 135 feet with an accuracy of 1/8 inch. There are six laser measure modes including distance, continuous, area, volume, Pythagorean method-two points (the tool measures two sides of a right triangle and then the device calculates the length of the third side automatically), and Pythagorean method-three points (establish a baseline, measure the hypotenuse, measure the adjacent leg and then the laser measurement tool will use these two measurements and the Pythagorean theorem to calculate the remaining leg, which represents the height or length of the object the user could not measure directly). The measuring device is primarily used in the home and construction industries, measures 0.79 inches long by 1.38 inches wide by 2.76 inches high, and weighs 90 grams. The laser measurement tool mainly consists of a Vietnamese engine Printed Circuit Board Assembly (PCBA) and charging PCBA, and a Taiwanese laser diode. Additional Chinese components include a lens, module housing, display, screen panel, silicone buttons, lithium battery, light guide component, flexible printed circuit (FPC) button, shell, warning label, screws, charging port plug, black wire, movement foam, and screen foam. Specifically, each laser measurement tool is comprised of a total of twenty-eight main individual components, eighty-five components that make up the engine PCBA, and twenty-five components that comprise the charging PCBA. The engine PCBA includes numerous Chinese components being placed using surface mount technology (SMT). These components include capacitors, suppressors, a semiconductor, photonics, an FPC connector, inductance, resistors, shielding, the printed circuit board (PCB), main chip, Electrically Erasable Programmable Read-Only Memory (EEPROM), Application-Specific Integrated Circuit (ASIC) chipset, and additional small components. The SMT process that creates the PCBA undergoes the procedures of pre-production preparation, stencil preparation and solder paste printing (choosing the proper laser-cut stencil with enlarged apertures for pads to ensure sufficient solder volume), automated component placement, and reflow soldering. Subsequently, the engine PCBA’s firmware is programmed to enable distance measurement, calculation, Human-Machine Interface (HMI) functions (e.g., display, keypad interaction) and power management. Finally, the charging PCBA is tested to make sure it has the ability to charge the lithium battery. The two PCBAs are then sent to China for further assembly and processing. In China, the engine PCBA, laser diode, lens and shell are assembled to the electric drive module (EDM) before creating the parameter settings. Meanwhile, the charging PCBA will be retested to make sure it is in good condition. Finally, the EDM module and charging PCBA are assembled with the other components (including the display, button, outer shell, etc.). When determining the country of origin, 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). Regarding the origin of the laser measuring tool, it is our view that the creation of the Vietnamese engine and charging PCBAs provide the essence of the finished laser measurement tool, including the measurement capability. The additional assembly process performed in China is not complex and does not transform the PCBAs into a new article with a different name, character, or use. Therefore, it is the opinion of this office that the country of origin of the laser measuring tool is Vietnam. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division