U.S. Customs and Border Protection has issued a final determination concerning the country of origin of certain LED display panels that may be offered to the U.S. government. Any party-at-interest may seek judicial review of this determination by July 15.
According to CBP, the devices at issue are capable of producing high-definition video or photographic images and are used in commercial and educational settings as signage or digital displays, including in large-format settings such as concert backdrops or film sets. They consist of two major sub-assemblies: a module board that drives and controls each LED unit, forming images for display, and a cabinet housing that encases the device and provides the power supply function.
The module board is assembled in Taiwan and comprises two subassemblies also assembled in Taiwan: (1) the main printed circuit board assembly with LED lamps, and (2) the HUB board and receiver card. The cabinet is composed almost entirely of Chinese-origin components and contains a power supply adapter board, power supply, motor assembly, power signal combination connector, and wall controller.
In ruling HQ H332752, CBP concluded that the country of origin of the devices is Taiwan because the assembly of the main PCBA in Taiwan results in a substantial transformation. Of particular importance, CBP stated, is that the PCBA enables the devices to distribute power to the LED lamps and therefore imparts the character of the devices.
CBP issues country of origin advisory rulings and final determinations as to whether an article is or would be a product of a designated country or instrumentality for the purposes of granting waivers of certain “Buy American” restrictions in U.S. law or practice for products offered for sale to the U.S. government. For more information on BAA requirements or restrictions, please contact Mark Segrist, Mark Tallo, or Josh Rodman.
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