The country of origin of a spectrophotometer

N350750
July 16, 2025
OT:RR:NC:N1:105
CATEGORY: Origin Michael Hansberry Datacolor, Inc. 5 Princess Road Lawrenceville, NJ 08648 RE: The country of origin of a spectrophotometer Dear Mr. Hansberry: In your letter dated June 27, 2025, you requested a country of origin ruling on a spectrophotometer. Descriptive literature was provided for our review. The item under consideration is the DC1000 spectrophotometer, which is a benchtop instrument designed to measure the intensity of light across a specific range of wavelengths. It is intended to analyze the color and spectral properties of samples in various industries. It operates by illuminating a sample with light and measuring the amount of light absorbed or reflected at different wavelengths, thereby providing detailed information about the sample’s color and composition. The DC1000 is made up of several different articles. The first is the SPX-Spectrophotometer Sub-Assembly, which is a U.S.-origin dual beam spectrophotometer assembly capable of splitting light from a sample and reference channels across the visible spectrum. This is the central sub-assembly in the completed DC1000 spectrophotometer for functionality and accuracy of color measurements. The SPX-Spectrophotometer sub-assembly is solely sourced from the United States where all manufacturing steps including procurement, assembly, testing, packaging, and stocking is performed. The SPX-Spectrophotometer sub-assembly is then shipped to China for further assembly into the final DC1000 machine. The next component is the power supply. The DC1000 utilizes an 85–264 volts AC input capable of providing DC output voltages of +5v, +24V, +12v, and -12V. This power supply is produced in the United States by a third-party supplier. The final sphere subassembly, also known as an “integrating sphere,” is used to measure the total light power of a source in order to allow illumination or reflection onto an object outside of the sphere. It is a hollow spherical cavity with its interior coated in barium. Other than the barium coating, which is mostly sourced from Italy with a small quantity of purchases coming from Germany or the U.S., the rest of the subassembly is of Chinese origin and assembled in China before further incorporation into the final assembly.

The filter wheel sub-assembly is designed to allow selective transmitting of specific wavelengths of light to the detector (i.e., the SPX-Spectrophotometer sub-assembly), enabling the measurement of light intensity at different wavelengths. The assembly consists of a rotating disk that holds multiple optical filters, each designed to transmit a particular range of wavelengths while blocking others. By rotating the wheel, the spectrophotometer positions different filters in the light path, isolating and measuring light at these specific wavelengths. The filter wheel sub-assembly is assembled in China with Chinese-origin components before further incorporation into the final assembly. The flash lamp serves as a light source, providing the broad-spectrum illumination necessary for accurate spectral analysis. It emits a wide range of wavelengths, covering the visible spectrum and often extending into the ultraviolet (UV) and near-infrared (NIR) regions, which allows for analyzing the color and optical properties of samples. The flash lamp is assembled in China with Chinese-origin components before further incorporation into the final DC1000. The zoom lens allows for adjusting the focus and magnification of the optical system to ensure accurate measurement of the sample’s spectral properties. The zoom lens allows the spectrophotometer to adapt to different sample sizes and shapes by altering the focal length, which helps in precisely directing and focusing the light onto the sample area of interest. The zoom lens is assembled in China with Chinese-origin components before further incorporation into the final assembly. The reference beam serves as a baseline or standard against which the sample beam is compared. Typically, the light source is split into two paths: one directed towards the sample and the other towards a reference detector. The reference beam accounts for any fluctuations in the light source intensity, environmental conditions, or instrument performance, ensuring that these variables do not affect the measurement of the sample’s optical properties. The reference beam is assembled in China with Chinese-origin components before further incorporation into the final assembly. In addition to the components listed above, there are also several printed circuit board assemblies (PCBAs) in the final spectrometer. The G400D is a computer memory module and PCBA manufactured in the U.S. and is supported by a U.S. firmware framework, allowing the manufacturer to write their own software that runs as an application on their framework. It is the “brains” of the entire product and runs the main software that controls the user interface, display, camera, color measurements, and all peripherals. It is a daughter card that eventually plugs into the SO-DIMM connector on the Motherboard. The G400D is of U.S. origin and gets shipped to China for final assembly into the finished article. All surface mounting technology (SMT) takes place in the U.S. prior to arrival in China. The Motherboard is a carrier board for the G400 and supplies power to it. It also provides all the connections from the G400’s SO-DIMM connector to all the unique interfaces and peripherals to the rest of the unit and the outside world. These include, but are not limited to: USB, Ethernet, Serial, Display, Camera, temperature sensor, the interface to the Analog board, and more. The Motherboard provides the central support, power, and connection of everything inside the unit. The Motherboard is produced in the United States. The Analog board is a low-level hardware interface that controls and operates the color measurement circuitry. It uses an ATmega1284P AVR processor to control the very precise timing of the high voltage charging, xenon flash, and spectrometer data read out. It performs this at the command of the Motherboard and reports the measured data back to the Motherboard in response. The Analog board is of U.S. origin. It will be sent to and connected with the Motherboard / G400 in China. The DC1000 also includes ten miscellaneous PCBAs that are all produced via SMT processes that occur in the U.S. These PCBAs supports functions of the various DC1000 instrument sub-systems and are attached together in China during the final assembly process.

All subassemblies are assembled to one another in China. Sub-assembly incorporation of the SPX-Spectrophotometer, final sphere, filter wheel, flash lamp, zoom lens, reference beam, and PCBAs, are generally assembled in China by using benchtop and non-electrical tooling (such as a torque screwdriver, thread-locker, glue, and computers with which to test software) to connect the individual parts of each unit together. Each step, from processing tiles and applying barium coating to assembling spheres, soldering wires, and final packing, include spray applications, soldering, wire routing, optical alignment, and data collection. Following the assembly process in China, the DC1000 will be shipped to the U.S. where it will undergo various post-assembly processes prior to sale to third party customers. These post-assembly processes include unboxing, optical alignment, instrument setup and testing, quality verification testing, data collection, visual assessment, and repackaging. When determining the country of origin, 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). Regarding the country of origin of the DC1000, it is our opinion that the assembly process performed in China is not complex and does not constitute a substantial transformation. The process predominately involves taking the pre-constructed components and screwing and snapping them into place. The combining of these articles does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the origin of the DC1000, we rely on the origin of the SPX-Spectrophotometer Sub-Assembly and PCBAs which provide the essence of the finished spectrophotometer. These devices include the measuring components necessary for the spectrophotometer to operate. The SPX-Spectrophotometer and PCBAs are manufactured and substantially transformed in the U.S. before being shipped to China. Accordingly, the country of origin for the DC1000 spectrophotometer will be the United States, which is where the SPX-Spectrophotometer Sub-Assembly and PCBAs are manufactured. 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 Forkan Acting Director National Commodity Specialist Division