The country of origin of LED lights

N354016 October 16, 2025 OT:RR:NC:N4:410 CATEGORY: Origin Fay Jin GreatStar Industrial USA, LLC 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of LED lights Dear Mr. Jin: In your letter dated September 22, 2025, you requested a country of origin ruling on LED lights for purposes of applying current trade remedies. The merchandise at issue is four models of LED lights identified as under-cabinet light, headlamp, utility light, and pivot spotlight. LED under-cabinet light Each light is comprised of a total of twenty-one (21) individual components. The major components include an LED PCBA (Printed Circuit Board Assembly), a control PCBA, an ABS (Acrylonitrile Butadiene Styrene) cover, an ABS battery compartment, a lens, a polarity connector, AAA batteries, etc. Particularly, the control PCBA consists of nineteen (19) discrete components, and the LED PCBA consists of six (6) discrete components. Headlamp Each light is comprised of a total of nineteen (19) individual components. The major components include a PCBA, which the control PCBA and LED PCBA are combined in a circuit board, an ABS cover, an ABS battery compartment, a lens, a Li-Ion rechargeable battery, etc. Particularly, the control PCBA consists of nineteen (19) discrete components, and the LED PCBA consists of thirteen (13) discrete components. Utility light Each light is comprised of a total of forty-nine (49) individual components. The major components include an LED PCBA, a control PCBA, an ABS cover, an ABS battery compartment, a lens, a Li-Ion rechargeable battery, etc. Particularly, the control PCBA consists of forty-one (41) discrete components, and the LED PCBA consists of sixty-one (61) discrete components. Pivoting spotlight Each light is comprised of a total of seventy-two (72) individual components. The major components include an LED PCBA, a control PCBA, an ABS handle, an ABS battery compartment, a lens, a polarity connector, rechargeable batteries, etc. Particularly, the control PCBA consists of one hundred and twenty-one (121) discrete components, and the LED PCBA consists of two (2) discrete components. You present a manufacturing process scenario for the LED lights which is summarized as follows: The components are imported into Thailand where they will first be made into the PCBA and the SMD LED sub-assembly with the discrete components (circuit board, LED, resistor, capacitor, infrared induction probe, 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. Specifically, the SMT process that creates the PCBAs undergo the procedures of pre-production preparation, stencil preparation and solder paste printing, automated component placement, reflow soldering, and manual soldering of positive/negative wires. Subsequently, these PCBAs and the SMD LED sub-assemblies will be sent to China and assembled with the balance of the Chinese-origin components, e.g., housings (including battery compartments), lenses, wires and buttons, metal hardware and accessories, etc., to produce the finished LED lights. 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 note that the PCBA and the SMD LED sub-assembly (light source) are fabricated in Thailand. They are the most important or critical components in the subject LED lights, which also impart the character of these LED lights. In addition, the LED chip-mounting operation and SMT process with other production operations performed in Thailand are complex and meaningful, thus, the substantial transformation has occurred. As such, the country of origin of the LED lights 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division