The country of origin of infrared forehead thermometers

N361128May 19, 2026OT:RR:NC:N1:105
CATEGORY: OriginTirta HalimT Customs Broker, Inc.5777 W. Century Blvd. #965Los Angeles, CA 90045RE: The country of origin of infrared forehead thermometersDear Mr. Halim:In your letter dated
April 29, 2025
, on behalf of your client, Fortunit Creative Co., Ltd., you requested acountry of origin ruling on infrared forehead thermometers.The items under consideration are infrared forehead thermometers (part numbers DET-306 and DET-3017).These devices measure human body temperature by detecting the intensity of infrared light emitted from theforehead. An infrared sensor receives this radiation, generating a voltage signal. Following amplification andanalog-to-digital conversion, this signal is sent to the Microcontroller Unit (MCU), where it is converted intoa temperature reading and displayed on the Liquid Crystal Display (LCD).These infrared forehead thermometers are intended for the intermittent measurement of human bodytemperature from the skin surface of the forehead. They are reusable and suitable for individuals of all ages inboth home and clinical settings. The thermometers measure core body temperature, which is the temperatureof a body’s vital organs. Specifically, they are designed to measure the temperature of the skin surface overthe temporal artery, a major artery of the head. The temporal artery is connected to the heart via the carotidartery, which leads directly from the aorta, the main trunk of the arterial system. This connection ensuresconstant blood flow, allowing body temperature changes to be reflected sooner in the forehead than in otherareas such as oral, rectal, or underarm sites.Both models are infrared forehead thermometers with fundamentally similar structures and processes.However, variations in appearance lead to slight differences in their plastic parts, display screens, and theappearance and dimensions of their Printed Circuit Boards (PCBs). Their five key components include adurable ABS plastic enclosure, a simple one-button control, a PCB integrating a thermopile chip and signalprocessing for high precision, a backlit LCD for clear readings, and the infrared sensor itself, which convertsdetected infrared signals into temperature.To manufacture the infrared forehead thermometers components are gathered from China and Cambodia. TheChinese components include the screen-printing transparency, conductive bar, LCD, backlight, battery
clamps, copper cap, screws, wire, transducer PCB, transducer, EVA spacer, buzzer, blister, insulation filmand the battery. The Cambodian components include the label, giftbox, manual, carton box, upper cover,lower cover, battery cover, test button, function button, measuring head and Chip-on-Board (COB). Thecomplete assembly is performed in Cambodia.In Cambodia, the assembly process begins with aligning the chip to the PCB solder pad, followed by hotpress welding and a functional test. Next, the ET sensor pins are inserted through the PCB holes, soldered,trimmed, and their three wires are welded. For the measuring head assembly, the sensor PCB is positionedonto the sensor base, and all components are secured with screws. Subsequently, the ET buzzer is assembledby soldering wires to porcelain pieces, then soldering the buzzer sheet to the two pads of the COB. Thebuzzer wire is then glued into its cavity. Following this, the sensor wires are soldered to the COBs weldpoints, and the LCD screen is pressed into place. The buttons are then assembled, the COB is placed insidethe plastic cover and screwed down, and the battery clip is assembled. Finally, the upper and lower covers arescrewed into place, completing the assembly.When determining the country of origin for purposes of applying current trade remedies under Section 301,the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter H301619, datedNovember 6, 2018. The test for determining whether a substantial transformation will occur is whether anarticle emerges from a process with a new name, character, or use different from that possessed by the articleprior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). Thisdetermination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).In this instance, the Cambodian-produced components provide the essence of the infrared foreheadthermometer. In our opinion, the assembly process performed in Cambodia is fairly simple, however, corecomponents such as the COB and measuring head are produced in Cambodia. The Chinese components helpcomplete the manufacturing process but do not provide the enabling technology that provides the essentialoperation elements for the infrared forehead thermometers (part numbers DET-306 and DET-3017) to work.In view of these facts, the country of origin is Cambodia.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Jason Christie at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division