The country of origin of an Electronic Shelf Label

N362758 July 22, 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 an Electronic Shelf Label Dear Ms. Murrin: In your letter dated June 30, 2026, you requested a country of origin ruling on behalf of your client, Boe Vision Electronic Technology Mexico, for an Electronic Shelf Label (ESL). The merchandise under consideration is described as an ESL, model EL01990101. The ESL is a wireless electronic display device, used in retail environments to display real-time product pricing and related information on the shelf edge. The ESL receives pricing and product data wirelessly from a store management system, processes the data, and updates the information on an electronic paper screen. The ESL is powered by a replaceable battery and communicates with store infostructure via wireless protocols. The manufacturing process for the ESL begins in China with the manufacturing of the Electronic Paper Display (EPD) Module. The completed EPD Module is shipped to Mexico. In Mexico, the main Printed Circuit Board Assembly (PCBA) is produced via a Surface Mount Technology (SMT) process. During this process, electronic components, such as multilayer ceramic capacitors (MLCCs), resistors, inductors, integrated circuits, diodes, connectors, oscillators, etc., sourced from various countries of origin, including China, Japan, the Philippines, United States, Taiwan, and Malaysia, are placed and soldered on a bare printed circuit board (PCB), sourced from China. Lastly, the final product assembly occurs in Mexico. The Mexican-produced PCBA is electrically connected to the Chinese-sourced EPD module. Firmware is then programmed into the device, the unit is assembled into its housing, labeled, subjected to testing, and packaged 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). Based on the facts presented, it is the opinion of this office that the PCBA of Mexican origin, which controls all the operations of the ESL, is the fundamental functional component for the functional ESL. The PCBA is responsible for receiving the pricing and product data, processing that data, and generates and sends control signals and display instructions to the EPD module. In view of these facts, the country of origin for the Electronic Shelf Label, model EL01990101 is Mexico 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