The country of origin of a display module

N358486 February 27, 2026 OT:RR:NC:N2:208 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a display module Dear Ms. Murrin: In your letter dated February 3, 2026, you requested a country of origin ruling on behalf of your client AUO Corporation. The merchandise under consideration is an AUO 14-inch display module, model number B140UAN08.4, which is designed for integration into notebook-style personal computers and industrial machines. This module is a color active-matrix liquid crystal display (AM LCD), composed of a TFT LCD panel, a driver circuit, and an LED backlight system. As per the information provided, this display module cannot process or convert a video or an ADP signal. The components are sourced from Taiwan and China. In Taiwan, the TFT-LCD cell is manufactured. First, the array glass panel (glass substrate) process occurs, which consists of unpacking and cleaning the glass substrates, thin film deposition (physical and chemical vapor deposition), photo-resist coating, ultraviolet (UV) exposure, development, wet and dry etching, stripping, ANI utilizing an annealing oven, coating and dissolving, array and AOI testing, and robot transfer. Next, the color filtering takes place. Then, the liquid crystal dispensing and cell packaging process is done, which creates the cell glass panel. This consists of polyimide printing, rubbing, sealant dispensing, liquid crystal dispensing, vacuum assembly, back side ITO, cutting, and polarizer lamination. The finished cells are then shipped to China for assembly. In China, the printed circuit board (PCBA) is bonded and the display module assembly is completed. This entails backlight inspection, assembly of the cell tape and panel, power-on aging, testing, and packaging. 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 are the dominant component that provides the character of this finished flat-panel display module that cannot process or convert signals. The complex manufacturing process performed in Taiwan renders the end use of the cells predetermined, as they cannot be used for any other purpose than a display. Therefore, the country of origin of this TFT LCD module that cannot process or convert a signal is Taiwan. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division