OT:RR:NC:N4:410
Jonathan Park
Jonathan & Associates CHB Services Inc.
1501 E Orangethorpe Avenue, Suite 140
Fullerton, CA 92831
RE: The country of origin of the LED lighting fixtures
Dear Mr. Park:
In your letter dated June 5, 2025, on behalf of Gigatera Communications, you requested a country of origin
ruling on the LED lights for purposes of marking, as well as for applying current trade remedies under the
301 tariffs, IEEPA tariffs and reciprocal tariffs.
The merchandise at issue is identified as SFP800 LED Sportlighting Luminaire (sportlighting luminaire). In
your description you state that the sportlighting luminaires are designed for illuminating large-scale sports
venues such as stadiums, arenas, and professional sports fields to ensure optimal visibility during games and
events held during nighttime or low ambient light conditions. You describe that each of the lights consists of
an integrated LED driver mounted within a die-cast aluminum housing, which holds multiple LED modules
(LED light source) and precision optics. The products are designed to be mounted on sports lighting poles or
stadium roof structures using adjustable mounting brackets.
You further state that the LED modules utilize high-power LEDs mounted onto metal-core printed circuit
boards for superior heat dissipation. They are paired with lens optical components to provide various beam
angles optimized for sports lighting uniformity. The lighting fixtures feature durable materials such as
corrosion-resistant die-cast aluminum for the housing, electro-deposition coating, and stainless steel external
hardware to ensure longevity in outdoor environments. The sportlighting luminaires are powered via an
external LED driver which is compatible with common external LED drivers with inputs of 200~480 VAC
depending on installation and dimming needs. These lighting fixtures include a galvanized steel adjustable
mounting bracket with aiming indicators for precise positioning on sports lighting poles or stadium
structures.
The submitted materials present that the manufacturing process starts with the production of the LED PCB
(Printed Circuit Board) SMD (Surface Mount Device) modules (the light sources) in South Korea. Upon
receipt of components and materials from China, Vietnam and local suppliers, the Korean factory undergoes
the IQC (Incoming Quality Control) and the following procedures:
Solder paste is printed onto the metal printed circuit boards, also called the bare boards.
LED chip, shield can, and connector are placed on the soldered areas.
The PCBs are loaded into the SMD reflow soldering equipment to perform SMT.
Power is then supplied to the completed LED PCB modules using a DC power supply to confirm that
the LEDs turn on properly.
Modules that passed the inspection go through OQC (Outgoing Quality Control), then are shipped to
the factory in Vietnam.
The factory in Vietnam will produce the light housings, gaskets, the LED drivers, etc., and then combine
these Vietnamese origin components and materials, and other components and materials imported from
Germany and China to make the finished sportlighting luminaries.
The assembly process in Vietnam includes the following procedures:
The PTX (Plate Thermal Exchanger) is press-fitted into the main housing casting.
Various finger guides are assembled.
The assembled main housing is sent to a local vendor in Vietnam for electrodeposition coating.
Once coated, the LED PCB SMD module is attached using thermal grease.
The LED PCB is connected via a cable gland and powered. Inner Visor A and B are assembled
respectively.
Once the inner visors are in place, the lenses are inserted between them and fastened with screws.
After fastening all screws, a gasket is attached to the glass. The gasketed glass is then placed on the
housing and fastened with screws onto the cover.
The completed parts and subassemblies are sent to the assembly line for final assembly, which includes the
following procedures:
The SMPSs (Switched Mode Power Supplies) are assembled into the main housings. The SPDs are
assembled into the housings and connected to the SMPSs input cable using WAGO connectors.
The SMPS output cables are also connected using WAGO.
Current settings are configured according to customer specifications using the software application
provided by the SMPS manufacturer.
Once current setting is completed, the junction cover gasket and cover are fastened.
Final output voltage and current are measured, and test results are printed. Products that pass are
moved to the final line for assembly with the LED light module.
Assemble the power driver to the LED light module using the prepared bracket.
Once assembly is complete, perform the final performance inspection. If results are satisfactory,
attach product label and proceed with packaging.
When determining the country of origin for purposes of applying current trade remedies under Section 301,
the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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. Friedlander & 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 on the information presented in the manufacturing scenario, this office is of the view that the
Korean-originating PCBs with the LEDs populated, which are the light sources and the considered the most
important components of the LED lights, have a pre-determined end-use when imported into Vietnam. They
do not undergo a change in use due to the assembly process in Vietnam. Therefore, the country of origin of
the LED sportlighting luminaries will be Korea for purposes of marking, as well as for applying current trade
remedies under the 301 tariffs, IEEPA tariffs and reciprocal tariffs.
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 Michael Chen at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division