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CBP Says UPanelS LED Display Panel Models Have Taiwan as Country of Origin

CBP has ruled that various models of LED display panels sold under the UPanelS brand undergo substantial transformation in Taiwan during the manufacturing process for its printed circuit board assembly (PCBA) and light-emitting diode (LED) lamp assembly. The agency said the components are largely sourced from China and Taiwan, but they are substantially transformed in Taiwan when made into UPanelS devices.

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Parent company Unilumin USA in September 2021 asked CBP to determine the country of origin of the LED display panel models for purposes of Title III of the Trade Agreements Act of 1979. That act oversees government procurement.

Parties-at-interest may seek a judicial review by July 15, CBP said in a June 14 Federal Register notice. The decision was issued June 10.

The UPanelS product line consists of a series of display units capable of producing high-definition video or photographic images differentiated primarily by pixel pitch. The UPanelS devices are used in commercial and educational settings as signage or digital displays, including in large format settings such as concert backdrops or film sets.

In accordance with past proceedings, CBP found that the assembly of the main PCBA in Taiwan results in a substantial transformation. While there is processing in China consisting of “installing” and “attaching” the subassemblies together for testing, it “is not sufficiently complex and meaningful to result in a substantial transformation. Based on the information provided, we therefore conclude that the processing in Taiwan results in a product with a new name, character, and use, i.e., an LED device capable of forming and displaying images,” CBP said.