The country of origin of Active-Matrix Liquid Crystal Display (AMLCD) modules

N359279 March 17, 2026OT:RR:NC:N2:208 CATEGORY: OriginGena HaddockExpeditors Tradewin795 Jubilee DrivePeabody, MA 01960RE: The country of origin of Active-Matrix Liquid Crystal Display (AMLCD) modulesDear Ms. Haddock:In your letter dated February 27, 2026 , on behalf of your client AUO Corporation, you requested a country oforigin ruling.The merchandise under consideration is color Active-Matrix Liquid Crystal Display (AMLCD) modules,model numbers B160UAN04.7, B140UAV05.1, B160UAV01.1, B140UAK03.H, and B160UAK01.7, whichare comprised of TFTLCD panel, a driver circuit, and LED backlight system. The subject flat panela-an display modules are all designed for a display unit of a notebook-style personal computer or industrialmachine. These modules display image signals but do not perform any form of video signal processing,encoding, decoding, or conversion. Model numbers B140UAK03.H and B160UAK01.7 contain atouchscreen.The components are sourced from Taiwan and China.The following manufacturing and assembly processes occur in Taiwan for each module. First, the array glasspanel substrate is unpacked and cleaned. Then, the thin film depositions, photo resist coating, ultraviolet lightexposure, development, etching, stripping, ANI (anneal oven), photolithography etching, array testing, androbot transfer occur. Next, the color filter (CF) , which includes unpacking and cleaning the glassis donesubstrate, photoresist coating, high performance curing process, in-line thickness, exposure, development,photo oven, AOI test, ITO, oven-sputter, CF repair, coating and dissolving processes. Then, the liquiding,crystal dispensing and cell packing . This process consists of polyamide printing, rubbing, sealanttake placedispensing, liquid crystal dispensing, vacuum assembly, back side ITO, cutting, and polarizer lamination. These processes create the finished TFT-LCD cell.In China, the PCBA is manufactured and the final assembly takes place. The functions of the PCBA include,receiving and displaying pre-processed signals.The assembly process includes backlight inspection, cell and backlight alignment, assembly of cell tape and panel, testing, and packing. When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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 completed LCD cells, regardless ofwhere they are cut to size, are the dominant component that provides the character of the finished flat paneldisplay modules. The complex manufacturing process performed in Taiwan renders the end-use of the cellspredetermined, as they cannot be used for any other purpose than a display. Further, the assembly processesperformed in China would not substantially transform the cells into new and different articles of commercewith a name, character, and use distinct from that of the exported good. Accordingly, based upon the factspresented, the country of origin of the subject modules is Taiwan.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Lisa Cariello at lisa.a.cariello@cbp.dhs.gov. Sincerely, (for)James ForkanDesignated Official Performing the Duties of the Division DirectorNational Commodity Specialist Division