The country of origin of integrated circuits

N350711
July 10, 2025
OT:RR:NC:N2:209
CATEGORY: Origin 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