The country of origin of LED mirrors

N358153 February 20, 2026 OT:RR:NC:N1:126 CATEGORY: Origin Laura Oliver A. N. Deringer 167 West Service Road Champlain, NY 12919 RE: The country of origin of LED mirrors Dear Ms. Oliver: In your letter dated January 23, 2026, you requested a country of origin and marking ruling on behalf of your client, Fleurco. The merchandise under consideration is a framed, wall mounted LED mirror marketed under the “Halo” product line. The mirrors feature integrated LED lighting (240 bulbs per meter), a built-in defogger, and dual touch-button controls. The finished product is imported into the United States equipped with a North American electrical plug and is designed to operate using a standard household electrical outlet. From the information you provided, sheets of float glass are manufactured in Thailand. A reflective backing is then applied to the float glass, permanently transforming it into a mirror. Each mirror is marked with a unique tracking number by the Thai supplier. These complete mirror sheets are exported from Thailand to China for further processing. In China, the Thai-origin mirrors are cut to the required dimensions and undergo edge-finishing operations such as grinding and chamfering. Designated areas on the back surface are processed to accommodate the functional features of the finished mirror. The mirrors are then combined with Chinese-origin aluminum framing, integrated LED lighting, wiring, defogging elements, and touch controls. Once assembled, the completed unit undergoes final testing, inspection, and packaging for export to the United States. 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country-of-origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. With regard to the Halo mirrors, the application of the reflective backing to the float glass in Thailand permanently transforms it into a mirror. While the processing performed in China enhances the functionality of the mirrors, it does not change their fundamental name, character, or use and does not constitute substantial transformation. Therefore, the country of origin of the Halo mirrors for marking purposes will be Thailand. 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 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 Yani De Leon at yaniri.deleon@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division