The country of origin of a liquid crystal lighting device

N352223
August 22, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Richard Suh Toshiba Logistics America, Inc. 501 Burning Tree Rd Fullerton, CA 92833 RE: The country of origin of a liquid crystal lighting device Dear Mr. Suh: In your letter dated August 11, 2025, you requested a country of origin ruling on behalf of your client, JDI Display America, Inc. The merchandise under consideration is identified as the LumiFree, which is described as a liquid crystal (LC) device. The device is comprised of multiple liquid crystal panels laid over the top of each other with printed circuit connectors on two sides. A control board is also included that is connected to the panels after importation. In use, the device is installed within an LED light source, such as an overhead lamp. The LC panel is placed over the bulb and, when wirelessly connected to a smart device or other module via the control board, alters the shape and distribution of the light within the area. This is achieved by the crystals within the panel being excited and moving in a way to change the light shape. We note that the device does not create any light and must be installed within a light source in order to perform its designated function. We note that we previously ruled upon the classification of this device under ruling letter N344651. In your request, you state that the manufacturing process begins in Japan with the creation of a liquid crystal panel by depositing a thin film of crystals onto a glass substrate. This panel is then sent to the Philippines where it is cut to the necessary size, and the flexible printed circuits (FPC) are attached. The modules then undergo a detailed optical bonding process before they are taped together in the correct configuration. The driving board, which is responsible for the control and programming of the device, is created via surface mount technology (SMT) in China and imported into the Philippines. The board and LumiFree module are then packaged together for shipment to the United States. We note that the module and driver board are not connected until after installation by the end user. 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). Regarding the origin of the subject device, it is the opinion of this office that the process performed in the Philippines imparts the optical properties of the device. As the device functions by interacting and altering the light which passes through it, we are of the opinion that this process creates the critical component of the device. Though the driver board is an important component, it only adds to the optical function and would not be considered the character of the finished article. Based upon the facts presented, the country of origin of the LumiFree will be the Philippines. 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 Luke LePage at [email protected].
Sincerely,
(for) James Forkan Acting Director National Commodity Specialist Division