OT:RR:NC:N2:209
In Cheol Kim
Magnachip Semiconductor
15F, 76 Jikji-daero 436beon-gil (Jikji Smart Tower), Heungdeok-gu, Chengju-si,
Chungcheongbuk-do, 28581
South Korea
RE: The country of origin of integrated circuits
Dear Mr. Kim:
In your letter dated June 26, 2025, you requested a country of origin ruling on an integrated circuit LED
backlight controller.
The item concerned is a semiconductor integrated circuit (IC) referred to as an LED backlight controller
model # “MAP3525BSIRH”.
This product undergoes front-end wafer fabrication in South Korea and back-end assembly in China.
The front-end manufacturing process that takes place in South Korea includes:
Wafer fabrication
Probe test
Coating
Exposure
Develop
Dry Etch
Wet Etch
PR Strip
Oxidation/Diffusion
LPCVD
Ion Implant
Chemical Vapor Deposition
Physical Vapor Deposition
Wafer Backside Process
Probe test
The essential identity of the product is established during the front-end wafer fabrication process conducted
entirely in South Korea. At this stage, the active circuitry and electrical characteristics are formed, including
diffusion layers, transistor gates, well regions, and metal interconnect layers. These processes collectively
define the logic and function of the final IC
The back-end manufacturing process that takes place in China includes:
Wafer Mount
Sawing
Die Bond
Wire Bond
Mold
PMC
De-Flash
Plating
Annealing
Marking
Trim/Form
The back-end assembly process in China, while necessary for physical packaging and shipment, merely
prepares the product for handling and use. This includes sawing the wafer, die attach, wire bonding,
encapsulation (molding), marking, and final inspection. None of these steps change the electrical design or
function that was already fixed during front-end manufacturing.
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 upon the facts presented, it is the opinion of this office that the front-end manufacturing process that
takes place in South Korea is both meaningful and complex, resulting in the creation of integrated circuits
which incorporate all the essential circuitry needed to function. The integrated circuits do not undergo a
substantial transformation as a result of the back-end manufacturing process that takes place in China. They
retain their identity as integrated circuits with a predetermined end use. Therefore, the country of origin of the
finished LED backlight controller IC, model # “MAP3525BSIRH” will be South Korea.
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 [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division