The country of origin of a LiDAR Module

N359371 March 25, 2026 OT:RR:NC:N1:105 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a LiDAR Module Dear Ms. Murrin: In your letter dated March 3, 2026, on behalf of your client, Hesai (Thailand) Limited, you requested a country of origin ruling on a Light Detection and Ranging (LiDAR) Module. Descriptive literature was provided for our review. The item under consideration is described as the Hesai OT128 LiDAR Module, which functions as a high-resolution, 360-degree automotive sensor for autonomous driving and smart logistics. The module creates detailed 3-dimensional maps for obstacle detection, navigation, and environmental awareness by using laser beams to measure distances. It provides core perception capabilities for L4 autonomous driving (robotaxis/robot trucks) and is applied to industrial automation scenarios such as smart ports, automated guided vehicles (AGVs), Autonomous Mobile Robots (AMRs), and service robots to enable precise navigation and obstacle avoidance. The OT128 LiDAR Module is composed of a Top Cover, Cover Lens, Lens Housing (also referred to as the opto-mechanical unit), and Base. The Lens Housing consists of the Lens Housing Semi-Finished Product (SFP), which includes the RX Module, TX Module, a series of lenses, the Top Main Board (TMB) Semi-Finished Product (this includes the TMB Board), and the Heat Sink Semi-Finished Product. Core components of the Lens Housing Semi-Finished Product (SFP) include the RX Module, TX Module, and a series of lenses. The TX Module is responsible for generating and sending out pulses of laser light into the environment. The TX Module includes the Transmitter Board, flexible printed circuit boards (FPC), front and back brackets, and a stop aperture. The RX Module is responsible for detecting the reflected light and enabling distance calculation. It includes the Receiver Front Board and Receiver Back Board, FPCs, a stop aperture, and a filter. The TMB SFP includes the TMB printed circuit board assembly (PCBA), which controls the timing of laser emission and reception, collects analog to digital converter (ADC) waveforms, calculates information such as distance and reflectance, and sends the packetized point cloud data to the Bottom Main Board (BMB) in the Base. The TMB SFP also includes the optical communication transmitter board of Chinese-origin. The BMB is part of the Base SFP and controls the wireless power supply module to power the optical engine, controls the rotation of the motor, collects encoder data to obtain real-time angle information, repackages the real-time point cloud data obtained from TMB, and then transmits it externally via the Ethernet. In your letter, you provide three separate manufacturing scenarios. The difference between the three scenarios is the country in which certain PCBAs undergo surface mount technology (SMT) assembly; all other assembly processes remain the same. Final assembly of the LiDAR Module occurs in Thailand in all three scenarios. In scenario I, the TMB PCBA, BMB PCBA, RX PCBA and TX PCBA are assembled in Thailand using standard SMT processes. All other components of the finished product are of Chinese origin. Subsequent assembly processes are completed in Thailand, and the finished LiDAR Module is shipped from Thailand to the United States. In scenario II, the TMB PCBA, BMB PCBA, RX PCBA, and TX PCBA are assembled in Vietnam using standard SMT processes. All other components of the finished product are of Chinese origin. The PCBAs and all other components are sent to Thailand where subsequent assembly processes are completed, and the finished product is shipped from Thailand to the United States. In scenario III, the TMB PCBA and BMB PCBA are assembled in Thailand using standard SMT processes. All other components of the finished product are of Chinese origin. The RX PCBA and TX PCBA are assembled in China using standard SMT processes and sent to Thailand for assembly into the RX and TX modules. Subsequent assembly processes are completed in Thailand, and the finished product is shipped from Thailand to the United States. Other than the changes in the manufacturing location for the various printed circuit boards, the assembly process of the LiDAR module occurs in Thailand. This assembly is predominately simple assembly where the various components are combined, screwed, snapped, and glued into place. The assembly consists of five types of stations. The automated station handles material loading and unloading, runs automated equipment, and disposes of products via prompts. The manual bonding station identifies adhesives, uses proper dispensing tools, and performs bonding and mounting. The manual fastening station identifies the correct screws, uses calibrated torque wrenches, and fastens screws. The manual station performs basic simple manual operations including loading, wiping, and handling. Finally, the quality inspection station conducts 100% inspection of products using specified tools. Various curing steps and testing steps are also completed once the module is fully assembled. 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Regarding the origin for scenario I, the TX and RX boards, which generate and detect the laser signal, together with the TMB, which handles timing, processing, and data capture, and the BMB, which controls system operations and communications, collectively provide the LiDAR’s essential function capabilities. In scenario I, these PCBAs are manufactured in Thailand. Additionally, the remaining subassemblies are also assembled in Thailand, and final assembly of the LiDAR Module takes place there. Accordingly, the country of origin for scenario I is Thailand. Regarding the origin for scenario II, the TX and RX boards, which generate and detect the laser signal, together with the TMB, which handles timing, processing, and data capture, and the BMB, which controls system operations and communications, collectively provide the LiDAR’s essential function capabilities. In scenario II, these PCBAs are manufactured in Vietnam. While there are additional Chinese components and final assembly in Thailand, it is the core PCBAs that provide the essence of the LiDAR modules functionality. Accordingly, in our opinion, the country of origin for scenario II is Vietnam. Regarding the origin for scenario III, the core PCBAs are produced in multiple countries (Thailand and China). No single PCBA solely defines the LiDAR Module’s primary functionality. Instead, the boards work collectively to deliver the device’s core sensing, signal-processing, and data-transmission functions. In scenario III, the TMB and BMB are manufactured in Thailand. The BMB collects encoder data to determine realtime angle information, repackages the point-cloud data generated by the TMB, and transmits it externally via Ethernet. The TMB manages the timing of laser emission and detection, collects ADC waveforms, computes distance and reflectance values, and sends the packetized point-cloud data to the BMB using optical communication. The TX and RX boards are assembled in China and perform the roles of laser emission and detection, the functions responsible for integrating the signal, managing timing, collecting ADC data, processing and packetizing point-cloud information, and transferring data, are carried out by the TMB and BMB manufactured in Thailand. In scenario III, the most meaningful processing occurs in Thailand, where two of the core PCBAs are produced and numerous critical subassemblies—such as the TX module, RX module, Lens SFP, and Lens Housing SFP—are completed. Thailand also performs firmware installation, final assembly, calibration, and full functional testing. Accordingly, the country of origin for scenario III is 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 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division