The country of origin of a flat panel display module

N356911
December 29, 2025
OT:RR:NC::N2:208
CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a flat panel display module Dear Ms. Murrin: In your letter dated December 10, 2025, on behalf of your client Innolux Corporation, you requested a country-of-origin ruling. The merchandise under consideration is a display module, identified as N160JCA-E5M, which is a 16-inch thin film transistor (TFT) Liquid Crystal Display (LCD) NB module with a light-emitting diodes (LED) backlight unit and 30-pin embedded display port (eDP) interface. As per the information provided, in its imported condition, this module cannot convert a video signal and is designed to be incorporated into a laptop after importation. The TFT LCD panel N35cell is manufactured in Taiwan. The production of the TFT LCD panel cell starts with array processing, including film deposition, photolithography, etching, TFT and pixel electrode formation, testing, and cleaning. Next, the color filter coating (RGB), exposure, and development occur, followed by cell processing (pre-PI cleaning, photo alignment, filling, and sealing). The finished TFT-LCD panel cell is then shipped to China. In China, the module assembly process takes place to form the complete flat panel display module. This process includes chip on glass (COG) bonding, outer lead bonding (OLB), printed circuit board (PCB) bonding, dispensing, PCB inspection, backlight assembly, module assembly, function check, surface pressuring, auto check optimum VCOM voltage, aging test, specification application programming, dimension check, dimension application programming interface, quality control, packing, serial number verification, etc. Once the final assembly process is completed, the module is shipped to the United States. 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 on the facts presented, it is our opinion that the completed TFT-LCD cells, regardless of where they are cut to size, are the dominant components that provide the character of the finished flat-panel display modules. The end use of the subject merchandise is predetermined by the complex manufacturing process performed in Taiwan, as they cannot be used for any other purpose than a display. Further, the assembly processes performed in China would not substantially transform the cells into new and different articles of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the country of origin of this TFT-LCD module is Taiwan. 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 Lisa Cariello at [email protected].
Sincerely,
(for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division