The country of origin of LED lighting systems

N356144 December 8, 2025 OT:RR:NC:N4:410 CATEGORY: Origin Anne Brandon Yormick Law LLC 5900 Landerbrook Drive, Suite 205 Cleveland, OH 44124 RE: The country of origin of LED lighting systems Dear Ms. Brandon: In your letter dated November 13, 2025, on behalf of Beta-Calco, you requested a country of origin ruling on LED lighting fixtures for purposes of applying current trade remedies. The merchandise at issue is identified as LED lighting systems, which include the Linear (Tunnel Pendant Continuous), Decorative (Oooh Quad) and Exterior (Sentinel). You state that the three lighting systems at issue consist of the same components with only minor changes based on customer specifications. You present the following manufacturing process for the LED lighting systems, in which the lighting systems are assembled in Canada from components sourced from the United States, Canada, and elsewhere, with each LED light product being built to order for the customer: The LED PCBAs (Printed Circuit Board Assemblies), which include the circuitry and LED diodes (light sources), are manufactured in the United States using SMT (Surface Mount Technology). The LED drivers are produced in Mexico, the United States, or China, and will be programed in Canada or the United States. The LED lighting system assembly operations in Canada are described as follows: 1. Lighting Fixture Frame Manufacture Tunnel Pendant Continuous Linear Lighting: a piece of extruded aluminum is cut to the customer-specified length. Oooh Quad Decorative Lighting: Similar to theTunnel Pendant Continuous Linear Lighting, extruded aluminum is cut to size. However, since the Oooh Quad decorative lighting has a non-linear square configuration, four pieces are welded together to achieve the desired design. Sentinel Exterior Lighting: The frame for the Sentinel exterior lighting is die-cast outside of Canada and imported into Canada pre-made. 2. Frame Processing Additional processing is performed on the linear and decorative frames based on customer specifications. This includes drilling holes to facilitate the attachment of components such as the driver, LED panel, and reflectors. For the Sentinel exterior lighting, certain elements are secured with adhesive. 3. Frame Painting The frames are painted using a paint line system, which involves cleaning the frame of impurities, painting in an automated spray booth, and curing the paint. 4. End Cap Assembly for Exterior and Linear Lighting Systems A bracket is attached to an end cap plate using a screw and washer. The assembled end cap plate is then secured to the frame with screws. 5. Driver Installation The driver is affixed to the frame using a washer and screw. 6. Reflector and LED panel assembly The reflector and LED panels are joined using clips. A bracket is then secured to the top of the reflector and LED panel using screws and washers. The assembled unit is then attached to the frame using the brackets. 7. Diffuser A diffuser is snapped into place on the exterior of the frame to cover the LED and reflector panel. 8. Optional Uplight Installation Certain products include an uplight, which is an additional LED panel secured to the top of the frame with brackets and washers. 9. Optional Assembly for Extended Lengths For linear lighting fixtures exceeding four feet in length, multiple sections are joined using brackets and screws. You further note that, in all instances where components are secured using screws and washers, a battery-operated screwdriver is utilized in the process. 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 LED PCBAs (light sources) are fabricated in the United States. They are the most important or critical components of the subject portable LED light, which also impart the character of the LED lights. In addition, the SMT process to manufacture the LED PCBAs in the United States is complex and meaningful. The operations in Canada do not substantially transform the LED PCBAs. It is our view that the country of origin of the subject LED lighting systems is the United States 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division