The country of origin of interactive panels

N353432 October 6, 2025 OT:RR:NC:N2:208 CATEGORY: Origin Lynlee Brown Ernst & Young LLP 18101 Von Karman Avenue, # 1700 Irvine, CA 92612 RE: The country of origin of interactive panels Dear Ms. Brown: In your letter dated September 8, 2025, on behalf of your client, Shiyuan (HK) Limited, you requested a country of origin ruling. The merchandise under consideration is an interactive flat panel (IFP), model number CG86VR. This 86-inch, high-resolution liquid crystal display (LCD) is designed for collaborative and engaging presentations. Its applications include corporate meeting rooms, classrooms, retail spaces, healthcare environments, etc. Moreover, the subject multi-touch displays have interactive whiteboards, wireless screen mirroring, real-time annotation, and pre-installed meeting software. There are two manufacturing scenarios for the interactive panel in question. In Scenario 1, the main board and LCD module are manufactured in China and will be shipped to Mexico. In Mexico, the finished IFPs are assembled, tested, and software upgrades are performed. In Scenario 2, the LCD modules are produced in China and shipped to Mexico. The manufacturing process of the main board, including the Surface Mount Technology (SMT) processes, is done in Mexico. The main board is a printed circuit board assembly (PCBA), which has multiple electronic components welded onto it. This board integrates and controls all main functions of the IFP, including managing communication and executing the software instructions that enable the interactive features. The PCBA manufacturing process includes installing micro-components onto bare printed circuit boards (PCBs) by SMT. The SMT assembly steps consist of SMT mounting, prefabricating chip devices onto a bare PCB, welding through hot air reflow, SPI (Solder Paste Inspection) detection, patch machine applications, automated optical inspection (AOI) detection, reflow soldering, etc. For both scenarios, the final assembly process of the CG86VR interactive flat panel display takes place in Mexico. The assembly process includes screwing, attaching, plugging, and locking the components together. Inspection, testing, upgrading the main program, and packaging also take place in Mexico. 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 interactive flat panel is the country in which the underlying main PCBA (main board) is produced. Accordingly, the Chinese or Mexican main board imparts the prominent character of the device, since it performs the primary and vital functions of the interactive display. Lastly, the assembly work conducted in Mexico does not substantially transform the main board PCBA into a new and different article. As a result, we find that the country of origin of the CG86VR interactive flat panel display is the country where the main PCBA is manufactured, in this case either China (Scenario 1) or Mexico (Scenario 2). 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, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division