OT:RR:NC:N2:209
Jody Shaw
Electronic Controls Company
833 W Diamond St
Boise, ID 83705
RE: The country of origin of Outdoor Pedestrian Boundary Line LED work lamps
Dear Ms. Shaw:
In your letter dated July 8, 2025, you requested a country of origin ruling on two models of signaling lighting
assemblies.
The items concerned are referred to as Outdoor Pedestrian Boundary Line LED work lamps (models #s
EW2025R and EW2025R-TOY). The EW2025R and EW2025R-TOY are rectangular LED work lamps
designed for use outdoors to establish a safety zone around the perimeter of a vehicle or heavy equipment
with a solid, colored beam of light. This lighting safety zone acts as a signal which is intended to grab
pedestrians’ attention. The EW2025R and EW2025R-TOY are virtually identical except for an additional
connector on the EW2025R-TOY and different packaging and labeling.
A complete description of the manufacturing process as well as the relevant bills of materials have been
submitted with the request.
The EW2025R and EW2025R-TOY are manufactured in both China and Thailand. The singular printed
circuit board assembly (PCBA) which contains all of the functional electrical components (LEDs, capacitors,
resistors, diodes, etc.) and which provides the illumination is manufactured in Thailand using surface mount
technology. The PCBA is then shipped to China where the final assembly occurs.
The Chinese assembly process consists of assembling the lens, base, connector cable and PCBA into the
finished goods. The base and connector cable are soldered to the PCBA. The PCBA is secured into the
housing by three screws. The PCBA and lens are glued and screwed into the housing. The finished goods
(EW2025R and EW2025-TOY ) are then exported to the United States from China.
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).
Based upon the facts presented, it is the opinion of this office that the manufacturing processes that take place
within Thailand to create the main PCBA is both substantial and complex. The character of this product is
imparted by the PCBA which would be considered the dominant component of this assembly. The
assembly/manufacturing process that takes place in China does not change the end use of the PCBA. The
PCBA does not undergo a substantial transformation as a result of the Chinese processing. Therefore the
country of origin of the finished Outdoor Pedestrian Boundary Line LED work lamps (models #s EW2025R
and EW2025R-TOY) will be the Thailand.
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