The country of origin of flat panel display modules

N359986
April 16, 2026
OT:RR:NC:N2:208
CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of flat panel display modules Dear Ms. Murrin: In your letter dated March 24, 2026, on behalf of your client Innolux Corporation, you requested a country of origin ruling. The merchandise under consideration is LCD-TFT display modules, model numbers N140JCG-VE9, N140JCN-E5K, N160JCA-VE2, and N160JCN-EEK, which are designed to be incorporated into notebook systems through a DisplayPort (eDP) connector. As imported, none of these modules contain electronics capable of processing or converting video or automated data processing (ADP) signals. Additionally, model numbers N160JCN-EEK and N140JCN-E5K include touchscreens. These display modules contain a TFT-LCD panel cell, IC drivers, a printed circuit board assembly (PCBA), a flex printed circuit (FPC), a backlight unit, and other minor components. The TFT-LCD cells are manufactured in Taiwan and considered the front-end process. This manufacturing process starts with the array process, which includes glass cleaning, film deposition, photolithography and etching, TFT and pixel electrode formation, and electrical testing. Next, the CF process consists of color filter coating (RGB), exposure, and development. After that is the cell process, where pre-PI cleaning, PI coating, PI main curing, photo alignment, LC filling, and sealing take place. Lastly, for the models with touch screens (N160JCN-EEK and N140JCN-E5K), the touch on display (TOD) process takes place. This process adds touch sensors directly onto the color filter (CF) glass using high-precision semiconductor lithography. The PCBAs are manufactured in China via a Surface Mount Technology (“SMT”) process. The function of the PCBAs is to provide panel driving, power management control, and backlight driver capabilities. During the SMT process, a bare printed circuit board is populated with electronic components that are mounted onto the board. The back-end manufacturing process is also performed in China and is described as involving the following steps: chip on glass (COG), outer lead bonding (OLB), PCBA dispensing, PCBA inspection, TOD-FPCA

bonding, TPI, post-assembly function check, surface pressure test, autocom, aging, TPI, specification application programming interface, specification check, dimension check, dimension application programming interface, output quality control, packing, and shipping. 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 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 purpose other than a display. 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 goods. 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) James P. Forkan Director National Commodity Specialist Division