The country of origin of an automotive display

N354175 October 16, 2025 OT:RR:NC:N2:209 CATEGORY: Origin Lynlee Brown Ernst & Young LLP 4365 Executive Drive, Suite 1600 San Diego, CA 92122 RE: The country of origin of an automotive display Dear Ms. Brown: In your letter dated September 24, 2025, you requested a country of origin ruling on an Ultra Light Emitting Diode Automotive Display (uLED Display Set), model # CN30UYX02.0, on behalf of your client, AUO Corporation. The uLED Display Set will be used by U.S. importers as an automotive display to project the car logo, charging status, and driving modes. The product utilizes microscopic LEDs to form individual pixels that provide precise display control and enhanced brightness and color. The manufacturing process of the uLED Display Set will take place in both Taiwan and China, with the most critical manufacturing steps taking place in Taiwan prior to importation into the U.S. The core parts of the uLED Display Set will be manufactured under two main processing steps that take place in Taiwan. The Taiwanese manufacturing process under Step 1A includes: Unpacking, Cleaning and Thin Film Deposition: The glass substrates are removed from packaging by a robotic arm and cleaned to prepare the substrates for the thin-film transistors (TFTs) array process. First, the glass substrate undergoes a physical vapor deposition (PVD) process, through a sputter machine, where films of metal materials are deposited onto the surface of the glass. Next, the glass substrate undergoes a chemical vapor deposition (CVD) process, through a CVD or sputter machine, where films of chemical materials are deposited onto the surface of the glass. Photolithography: Photo-resist coating is applied to the glass substrate. A coater system is used to apply photosensitive material uniformly across the entire glass substrate. Using an exposure machine, the glass substrate is irradiated with ultraviolet light, transferring onto it a high-precision TFT pattern via a mask. A developing system uses developer fluid to dissolve the photoresist previously applied, leaving only the resistant TFT pattern. Dry/Wet Etching and Stripping: Portions not covered by the photoresist are removed to form the transistor circuits. A dry etching machine decomposes the insulation film with a corrosive gas. A wet etching machine dissolves the metal film with a liquid chemical. A resist stripping machine is used to remove the photoresist. Array Testing and Packing: The glass substrate is tested by an array tester system, for both electrical and non-electrical defects. The glass substrate is placed by a robotic arm onto glass trays. The Taiwanese manufacturing process under Step 1B includes: Unpacking, Cleaning and Thin Film Deposition: The glass substrates are removed from packaging by a robotic arm and cleaned to prepare the substrates for the TFT array process. The main difference between the array process in Step 1B is that it does not use LTPS technology during the array process. Moreover, the array process in Step 1B begins with CVD. Films of chemical materials are deposited onto the surface of the glass through a CVD machine. The glass substrate then undergoes a PVD, through a PVD machine, where films of Metal materials are deposited onto the surface of the glass. Photolithography: Photo-resist coating is applied to the glass substrate. A coater system is used to apply photosensitive material uniformly across the entire glass substrate. Using an exposure machine, the glass substrate is irradiated with ultraviolet light, transferring onto it a high-precision TFT pattern via a mask. A developing system uses developer fluid to dissolve the photoresist previously applied, leaving only the resistant TFT pattern. Dry/Wet Etching and Stripping: Portions not covered by the photoresist are removed to form the transistor circuits. A dry etching machine decomposes the insulation film with a corrosive gas while generating ions to bombard the substrate surface. A wet etching machine dissolves the metal film with a liquid chemical. A resist stripping machine is used to remove the photoresist. The coating and dissolving process is then repeated generally five times to create the desired pattern for the TFT Array, which results in five different overlapping transistors. Array Testing, AOI Testing, Robot Transfer, and Cutting: The glass substrate is tested by an array tester system, for electrical defect. Then, the glass substrate is tested by Automated Optical Inspection (AOI) system for defects. The glass substrate is placed by a robotic arm onto a glass cassette storage rack. Finally, the combined substrate is next cut into desired dimensions using a glass cutting and grinding machine. The Taiwanese Electroless Nickel Immersion Gold (ENIG) Processing Step 1C includes: Shipping and Inspection: The array is shipped from the AUO site to another site for “ENIG” processing. Once the goods arrive, part numbers, quantities, and non-broken items are first checked. Defect Recording and Processing: Electroless nickel immersion gold (ENIG) is a metal plating process. It includes cleaning, micro etching, acid rinse, electroless nickel plating, and electroless gold plating. Packaging: The output is array glass substrate panel. The original packaging materials is used to pack the items and ship them back to the AUO. The Taiwanese manufacturing process under Step 1D includes: Delamination, Cleaning, Array testing, and Lamination: The process begins with the careful removal of the protective film from the panel. A FLUX cleaner is used to clean the panel. The array is then tested using an electrical input measurement. Next, the LED is temperately fixed on the template glass using glue. Cell Bonding Line: Cell bonding is the most critical step in the uLED production process. Any errors in bonding can result in display defects and reduced performance. First, the LED is transferred onto the template glass and inspected for accuracy. The glass template is then plasma etched to etch away any residues and prepare the bonding surface. The TFT panel is then FLUX coated to promote soldering before moving to the oven to evaporate the FLUX coating, resulting in a prepared surface for even bonding. Template glass sealant is applied to create a perimeter seal to prevent leakage. The template glass and uLEDs are placed in a vacuum environment to remove any air between layers. The uLED cells are then bonded to the TFT panel and the template glass is removed. Light on uLED, Optical Inspection, and Dispenser: The uLED is then illuminated to identify any defect positions, and an optical inspection is conducted to assess the uLED bonding position and detect any defects. If necessary, repairs are made to the uLED in the redundancy area. Additional protective film is applied to the COF area, and a molding film is used to protect the panel, which is then cured to secure the protection. The lead areas of the panel are covered to prevent damage in the molding process. A protective molding film is then applied over the panel and baked to ensure even adhesion. The molding film layer is removed, and the remaining molding area is etched away to expose certain areas. Finally, the etched molding layer is inspected for defects. Surface Treatment and Cutting: The uLED appearance is exposed from the panel, and CO2 is used to clear the surface and remove any particles. The COF protection film is removed, and the glass surface is pretreated. The glass is then cut from sheet to chip, preparing it for the next stages of processing. After Step 5 the uLED bonding to the panel is complete, resulting in the uLED display. Step 1D marks the point at which discrete components are integrated into a functional display unit. The transformation from individual uLED cells and TFT panels into a bonded, operational display. Processing: An optical film is laminated onto the panel, and efforts are made to reduce bubbles between the panel and the optical film. The panel is checked for Mura, and adjustments are made to improve color and lamination balance. Lamination and uniformity are measured to ensure quality. The Chip on Film and Film on Film Bonding Process that takes place in Taiwanese under manufacturing Step 2 includes: Cleaning and Preparation: The bonding process begins with cleaning the bonding area to ensure optimal bonding conditions. This step removes any contaminants that could interfere with the bonding quality, thereby ensuring a strong and reliable bond. Chip on Film (COF) Bonding: The COF is aligned and attached to the Anisotropic Conductive Film (ACF) on the glass substrate. When high temperature and pressure are applied to the ACF, it melts and binds the COF to the TFT-LCD glass substrate. This step creates a stable connection between the COF and the glass substrate. Quality Check and PCBA Bonding: After aligning and attaching the COF to the ACF on the glass substrate, a quality check is performed using a Lead Checker (or Akkon AOI) to ensure the bonding quality before proceeding to the PCBA bonding. The ACF is then attached to the desired bonding area of the PCBA, connecting it to the COF through the application of heat and high pressure. To prevent corrosion caused by moisture and foreign substances, a dispenser is used to seal the gap between the CF and COF cut line. Finally, operators conduct testing and visual inspection, to identify and address any defects that may have occurred during the bonding process. The Chinese Lamination process that takes place under Step 3 includes: Pre-Lamination: Before lamination, there is an electrical screen inspection test to ensure that the product is of good quality. Lenses are cleaned to avoid introducing foreign matter, dirt, and other defects into the machine. Lamination and Packing: After attaching the Cover Glass and Semi-panel, the product needs to go through a pressurized degassing furnace to apply a certain pressure and temperature to remove any pasting bubbles. Once this process is complete, perform functional confirmation testing and an appearance inspection. After confirming that the quality meets the specifications, the finished product is loaded into the tray. The Chinese Assembly Process that takes place under Step 4 includes: Assembly Process: The assembly of uLED, bezel, printed circuit board (PCB), and bracket (BRKT) is conducted on a highly automated production line. This ensures precise alignment and secure attachment of all components, optimizing the efficiency and consistency of the assembly process. Quality Control and Packing: The completed product undergoes rigorous quality control, including final functional testing to verify operational performance and visual inspection to ensure aesthetic standards are met. Once the product passes these quality checks, it is manually packed and prepared for shipping to the customer. 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 information provided, it is the opinion of this office that the uLED panel manufactured in Taiwan (Steps 1 and 2) impart the character of the finished article and would be considered the dominant component of the finished good. The various components used in the manufacturing process are substantially transformed into a different article with a new name, character and use as a result of the processing that takes place in Taiwan. The installation of the glass cover and final assembly process under Steps 3 and 4, that takes place in China, while important, will not change the character and end use of the product that was already realized in Taiwan. Therefore, since a substantial transformation does not occur as a result of the Chinese processing, the country of origin of the finished uLED Display Set, model # CN30UYX02.0, would be Taiwan upon importation into the United States. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division