The country of origin of thin-film transistor (TFT) liquid crystal display (LCD) modules

N354567 October 28, 2025 OT:RR:NC:N2:208 CATEGORY: Origin Richard Suh Toshiba Logistics America, Inc. 501 Burning Tree Road Fullerton, CA 92833 RE: The country of origin of thin-film transistor (TFT) liquid crystal display (LCD) modules Dear Mr. Suh: In your letter dated October 2, 2025, you requested a country of origin ruling on behalf of JDI Display America Inc. The items under consideration are thin-film transistor (TFT) liquid crystal display (LCD) modules, part numbers LPM096G588A and LPM096G590A, which are specifically designed for integration into automotive systems for the rearview mirror. These LCD modules do not function as a replacement component and do not have the ability to convert video signals. In Japan, the process starts with a glass substrate. During this process, multiple steps are performed in chemical vapor deposition machines to build up a TFT array structure on the substrate. Next, the color filter is developed on a matching and separate glass substrate. Then, the LCD panel is filled using a one-drop fill process, which is applied to the entire TFT array substrate, and the liquid crystal material is compressed between the TFT array side when the color filter glass substrate is added and aligned on top. This process creates a sheet of TFT-LCD cells that will later be cut into individual cells. In China, the substrate is cut into “chips” (individual LCD panels). After that, the module is assembled and completed by taking the LCD cell (chip) and affixing driver integrated circuits (ICs), polarizers, flexible printed circuits (FPCs), and then a backlight, frame, etc. Lastly, quality testing is performed. 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 our opinion that the completed TFT-LCD cells, regardless of where they are cut to size, are the dominant component that provides the character of the finished flat-panel display modules. The complex manufacturing process performed in Japan renders the end use of the cells predetermined, as they cannot be used for any other purpose than a display. Further, the cutting and assembly processes performed in China would not substantially transform the cells into new and different articles of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the country of origin of this TFT-LCD module is Japan. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division