OT:RR:NC:N4:410
Christopher LaVenture
Jasco Product Company
10 E Memroial Road
Oklahoma City, OK 73114
RE: The country of origin of LED light bars
Dear Mr. LaVenture:
In your letter dated July 2, 2025, you requested a country of origin ruling on LED light bars for purposes of
current trade remedies.
The merchandise is three models of LED lights identified as the Rechargeable Motion Sensing Light Bars,
Jasco Models 80876, 84409 and 84410.
You state that all models have the same construction but different in length. Each of the lights consists of the
following components and materials:
Aluminum enclosure
Top plastic end cap
Bottom plastic end cap
On/Off button
Dimmer button
Lampshade
Light guide panel
Reflective sheet
Magnet
Glue
Electronic yellow glue
Double tape
Leadwire
Main PCB (Printed Circuit Board)
Lamp PCB
Battery
LEDs
Metal sheet w/ 3M tape
Mainboard set screws
End cap set screws
Cable
All of these components are of Chinese-origin, except for the LEDs, mainboard set screws, end cap set
screws, and cable, which are made in Thailand. The Chinese-origin components and materials are shipped to
Thailand where they are combined with the Thai-made components to fabricate the finished LED lights.
The assembly process in Thailand begins with the production of the PCBAs, in which, the Chinese
origin-PCBs are populated with the Thai-origin LEDs via the SMT (Surface Mount Technology) process to
produce the light source.
The assembly operations following the SMT include 17 steps to assemble the components into a finished
light involving screwing, soldiering, taping, inspection and testing.
When determining the country of origin, 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).
We find that, although the overwhelming majority of components and materials are imported (of non-Thai
origin), the PBCAs (light source) are fabricated in Thailand. They are the most important or critical
components in the subject LED light bars, which also impart the character of the LED light bars. The SMT
process to create the light source along with other assembly operations performed in Thailand are complex
and meaningful, thus, the substantial transformation has occurred. As such, we are of the view that country
of origin of the LED light bars is Thailand for purposes of current trade remedies.
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)
James Forkan
Acting Director
National Commodity Specialist Division