The country of origin of an LED flashlight

N353302 October 3, 2025 OT:RR:NC:N4:410 CATEGORY: Origin John Schoenig GDLSK LLP 599 Lexington Avenue, Floor 36 New York, NY 10022 RE: The country of origin of an LED flashlight Dear Mr. Schoenig: In your letter dated September 5, 2025, on behalf of your client GreatStar Industrial USA, LLC, you requested a country of origin ruling on an LED flashlight for purposes of current trade remedies. The LED flashlight measures approximately 4.33 inches in length and 1.26 inches in diameter. The body is of steel tube construction. The luminescence of the flashlight can be changed by the user with a twist of the bulb head, with a maximum of 300 lumens. The LED flashlight consists of a plastic cover (lens), a reflecting cup, a PCBA (Printed Circuit Board Assembly), an SMD LED (Surface Mount Device and Light Emitting Diode) sub-assembly, a lamp holder, an aluminum alloy housing containing a battery holder and a tail cover with a power switch. Specifically, you state that each flashlight is comprised of a total of twenty-seven (27) individual components. This includes the nine (9) individual components that make up the printed circuit board sub-assembly and the (2) components that comprise the LED sub-assembly. We note that the fact pattern of this ruling request is identical to that in ruling N350710, dated July 21, 2025. In N350710, the PCBA and the SMD LED sub-assembly are made in Vietnam, which will be assembled with the balance of imported components to produce the finished flashlight in Vietnam. We determined that the country of origin of the LED flashlight is Vietnam for purposes of current trade remedies. In the instant scenario, the final assembly will occur in Vietnam or in other counties. Your submission indicates that all of the components are imported into Vietnam where they will first be made into the PCBA and the SMD LED sub-assembly with the discrete components (circuit board, LED, resistor, capacitor, MOS tube, dimming chip, etc.) through the LED chip-mounting operation and the Surface Mount Technology (SMT) process to fabricate the LED light source. The LED chip-mounting operation undergoes the procedures of stencil alignment, solder paste printing, solder paste inspection, LED chip placement, reflow soldering, automated optical inspection and functional testing. The SMT process that creates the PCBA undergoes the procedures of pre-production preparation, stencil preparation and solder paste printing, automated component placement, reflow soldering, and manual soldering of positive/negative wires in the SMT assembly. Subsequently, these PCBA and the SMD LED sub-assembly will be assembled with the balance of components sourced from various countries (e.g., Vietnam, China, Malaysia, etc.) to produce the finished flashlight, either in Vietnam or in other countries. 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). We find that the PCBA and the SMD LED sub-assembly (light source) are fabricated in Vietnam. They are the most important or critical components in the subject LED flashlight, which also impart the character of the LED flashlight. The LED chip-mounting operation and SMT process with other assembly operations performed in Vietnam are complex and meaningful, thus, the substantial transformation has occurred. As such, the country of origin of the LED flashlight is Vietnam with final assembly occurring in Vietnam or in other countries 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division