The country of origin of a portable LED light

N355502
November 17, 2025
OT:RR:NC:N4:410
CATEGORY: Origin Fay Jin Great Star Industrial USA, LLC. 9836 Northcross Center Court, Suite A Huntersville, NC 28078 RE: The country of origin of a portable LED light Dear Mr. Jin: In your letter dated October 30, 2025, you requested a country of origin ruling on a portable LED light for purposes of applying current trade remedies. The merchandise at issue is identified as LED Compact Spotlight, which is a portable LED light. The product images indicate that the light consists of a cylindrical light housing (body) with a light head and a handle attached, which contains an LED PCBA (Printed Circuit Board Assembly) for the light source, and two control PCBAs, an ABS battery compartment, a silver bowl, and rechargeable batteries. You state that there are two components that make up the LED PCBA, and twenty seven components that make up the two control PCBAs. You present a manufacturing process scenario for the portable LED light which is summarized as follows: The components and materials are imported into Thailand where they will first be made into the SMD LED sub-assembly and the PCBAs with the discrete components (circuit board, LED, etc.) through the LED chip-mounting operation and the Surface Mount Technology (SMT) process to fabricate the LED light source. The LED chip-mounting operation undergoes the procedures of stencil alignment, solder paste printing, solder paste inspection, LED chip placement, reflow soldering, automated optical inspection and functional testing. The SMT process that creates the PCBA undergoes the procedures of pre-production preparation, stencil preparation and solder paste printing, automated component placement, and reflow soldering. Subsequently, the PCBAs and the SMD LED sub-assembly will be sent to China and assembled with the balance of the components sourced from China to produce the finished portable LED light. 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). We note that the PCBAs and the SMD LED sub-assembly (light source) are fabricated in Thailand. They are the most important or critical components in the subject portable LED light, which also impart the character of the LED light. In addition, the LED chip-mounting operation and SMT process with other production operations performed in Thailand are complex and meaningful, thus, the substantial transformation has occurred. We also note that the subject product and the manufacturing process are akin to the manufacturing process scenario presented in N354016, dated October 16, 2025. In N354016, CBP determined that the country of origin for the LED lights is Thailand. Accordingly, the country of origin of the subject portable LED light is Thailand for purposes of current trade remedies. 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 Michael Chen at [email protected].
Sincerely,
(for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division