The country of origin of heads-up display modules

N359896 April 6, 2026 OT:RR:NC:N2:209 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of heads-up display modules Dear Ms. Murrin: In your letter dated March 19, 2026, you requested a country of origin ruling, on behalf of your client, CarUX Technology Pte. Ltd., for a heads-up display module. The item concerned is a display module, model DE026DC-02A. This device is an automotive heads-up display (HUD) module designed to project critical driving information, such as speed and navigation, onto a windshield. The module incorporates a 2.6-inch thin film transistor liquid crystal display (TFT-LCD) specifically engineered for heads-up image projection in vehicles. The major components consist of a glass substrate, liquid crystal material, color filter, thin film transistor (TFT), polarizer, Integrated Circuit (IC) drivers, stainless steel material, and a flexible printed circuit board assembly (FPCBA). The manufacture of the subject display consists of a front-end process performed in Taiwan and a back-end process conducted in China. The front end manufacturing process for the TFT-LCD cell substrate has three separate steps, all of which occur in Taiwan, they include: Production of the thin film transistor (TFT) array includes the following steps: 1. TFT glass substrate is cleaned and all impurities removed. 2. Plasma-enhanced chemical vapor (PE-CVD) deposition. 3. The addition of Silicon Nitride (SiNx) & Silicon Oxide (SiOx). 4. The addition of Amorphous Silicon (a-Si). 5. Excimer laser anneal. 6. Channel doping. 7. Gate electrode formation. 8. 8. N-type and P-type ion doping. 9. Source and Drain Electrode formation. 10. Planarization layer. 11. PVD is used to deposit transparent electrode layer. Production of the color filter (CF) substrate: 1. Black matrix is applied to CF glass substrate to define pixel boundaries and prevent color mixing. 2. Red photoresist coating is applied to CF glass substrate to create red pixels. 3. After removal of excess photoresist coating by the developing solution, the pattern is cured through baking. 4. Steps 2 and 3 are repeated using the green photoresist coating and blue photoresist coating to create green and blue pixels. 5. Overcoat layer is applied to create flat, uniform surface. 6. Photo spacer is formed using photolithography to control the cell gap between the CF and TFT array substrates. Production of the TFT-LCD cell substrate. 1. Polyimide layer is printed onto both the TFT array substrate and the CF substrate and baked. 2. The PI layer is photo-aligned so that it will align the liquid crystal molecules in the correct direction, then baked. 3. TFT array and CF substrate are baked to cure the PI layer. 4. Sealant is applied to the surface of the CF to create the boundaries in which the liquid crystal will be contained. 5. Liquid crystal is dispensed onto the TFT array. 6. The CF substrate is assembled on top of the TFT array, and the two substrates are sealed together to securely encase the liquid crystal. 7. The seal is cured. The back end of line (BEOL) processing that takes place in China includes the following: 1. Cutting. 2. Cleaning. 3. Polarizer attachment. 4. Light-On Test. 5. Packing for transport to liquid crystal module (LCM) processing. The (LCM) processing (Bonding and Assembly) includes the following: 1. Bonding Area Cleaning. 2. Chip on Glass (COG) Bonding. 3. FPCA Bonding (the FPCA is manufactured within Taiwan). 4. Glue/Tuffy Dispense. 5. Auto Optical Inspection. 6. Light-On Test. 7. Aging Test. 8. Bezel/Rear Assembly. 9. Optical Test. 10. Function Test. 11. Cosmetic Test. 12. OQC Sampling Test. 13. Packaging/Shipping. 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. Based upon the facts presented, it is the opinion of this office that the processing that takes place within Taiwan is both meaningful and complex, resulting in the creation of TFT-LCD cells. Accordingly, it is our opinion that the TFT-LCD cells, regardless of where they are cut to size, are the dominant component that provides the character to the finished display modules. The complex manufacturing process performed in Taiwan imparts the TFT-LCD cells with their predetermined end use. The manufacturing processes performed in China would not substantially transform the cells into new and different article of commerce with a name, character, and use distinct from that of the exported good. Therefore, the country of origin of the display module, model DE026DC-02A, will be Taiwan for marking purposes and for the purpose of applying current trade remedies and additional duties. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division