OT:RR:NC:N1:105
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin of a LiDAR Module
Dear Ms. Murrin:
In your letter dated July 27, 2026, on behalf of your client, Hesai (Thailand) Limited, you requested a country
of origin ruling on a Light Detection and Ranging (LiDAR) Module. Descriptive literature was provided for
our review.
The item under consideration is described as the Hesai OT128 LiDAR Module, which functions as a
high-resolution, 360-degree automotive sensor for autonomous driving and smart logistics. The module
creates detailed 3-dimensional maps for obstacle detection, navigation, and environmental awareness by
using laser beams to measure distances. It provides core perception capabilities for L4 autonomous driving
(robotaxis/robot trucks) and is applied to industrial automation scenarios such as smart ports, automated
guided vehicles (AGVs), Autonomous Mobile Robots (AMRs), and service robots to enable precise
navigation and obstacle avoidance.
The OT128 LiDAR Module is composed of a Top Cover, Cover Lens, Lens Housing (also referred to as the
opto-mechanical unit), and Base. The Lens Housing consists of the Lens Housing Semi-Finished Product
(SFP), which includes the RX Module, TX Module, a series of lenses, the Top Main Board (TMB)
Semi-Finished Product (this includes the TMB Board), and the Heat Sink Semi-Finished Product.
Core components of the Lens Housing SFP include the RX Module, TX Module, and a series of lenses. The
TX Module is responsible for generating and sending out pulses of laser light into the environment. The TX
Module includes the Transmitter Board, flexible printed circuit boards (FPC), front and back brackets, and a
stop aperture. The RX Module is responsible for detecting the reflected light and enabling distance
calculation. It includes the Receiver Front Board and Receiver Back Board, FPCs, a stop aperture, and a
filter. The TMB SFP contains the Top Main Board PCBA, which controls the timing of laser emission and
reception. Additionally, this PCBA collects analog-to-digital converter (ADC) waveforms and calculates
distance and reflectance. The resulting packetized point cloud data is then sent to the Bottom Main Board
(BMB) located in the Base. The TMB SFP also includes an optical communication transmitter board of
Chinese origin.
The BMB is part of the Base SFP and controls the wireless power supply module to power the optical engine,
controls the rotation of the motor, collects encoder data to obtain real-time angle information, repackages the
real-time point cloud data obtained from TMB, and then transmits it externally via the Ethernet.
In your letter, you provide two manufacturing scenarios. The difference between scenarios is the country in
which certain PCBAs undergo surface mount technology (SMT) assembly; all other assembly processes
remain the same. Final assembly of the LiDAR Module occurs in Thailand in both scenarios.
In scenario I, the TMB PCBA and BMB PCBA are assembled in Vietnam using standard SMT processes.
The RX PCBA and TX PCBA are assembled in China using standard SMT processes and sent to Thailand
for assembly into the RX and TX modules. Subsequent assembly processes and programming are completed
in Thailand, and the finished product is shipped from Thailand to the United States.
In scenario II, the TMB PCBA, BMB PCBA, and RX PCBA (RBB and RFB) are assembled in Vietnam
using standard SMT processes. All other components of the finished product, including the TX PCBA, are of
Chinese origin. The PCBAs and all other components are sent to Thailand where subsequent assembly
processes and programming are completed, and the finished product is shipped from Thailand to the United
States.
Other than the changes in the manufacturing location for the various printed circuit boards, the assembly
process of the LiDAR module occurs in Thailand. This process is predominantly a simple multi-stage
assembly where components are combined, fastened, snapped, and bonded into place. The assembly consists
of five stations. The automated station handles material loading and unloading, runs automated equipment,
and disposes of products via prompts. The manual bonding station identifies adhesives, uses proper
dispensing tools, and performs bonding and mounting. The manual fastening station identifies the correct
screws, uses calibrated torque wrenches, and fastens screws. The manual station performs basic simple
manual operations including loading, wiping, and handling. Finally, the quality inspection station conducts
100 percent inspection of products using specified tools. Various curing steps and testing steps are also
completed once the module is fully assembled.
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. Friedlaender & 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.
A substantial transformation occurs when, as a result of manufacturing process, a new and different article
emerges, having a distinct name, character or use, which is different from that originally possessed by the
article or material before being subjected to the manufacturing process. See United States v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).
Regarding the origin for the LiDAR module, the core PCBAs are produced in multiple countries (Vietnam
and China). No single PCBA solely defines the LiDAR Module’s primary functionality. Instead, the boards
work collectively to deliver the device’s core sensing, signal-processing, and data-transmission functions. In
scenario I, the TMB, which handles timing, processing, and data capture, and the BMB, which controls
system operations and communications, are assembled in Vietnam using SMT. The TX and RX boards are
assembled in China and perform the roles of laser emission and detection. In scenario II, the TMB, BMB and
RX boards are produced in Vietnam, while the TX board is produced in China. In both scenarios, the
firmware is installed, final assembly and combining of the core components occurs, calibration of the module
is completed, and full functional testing is done. In our opinion, this combining of the PCBAs sourced from
different countries and the additional processing performed in Thailand transforms the individual components
into a working LiDAR module. Accordingly, the country of origin for marking purposes for scenario I and II
is 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 Jason Christie at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division