H342474

H342474 October 21, 2025 OT:RR:CTF:VS H342474 JH CATEGORY: Origin Sergio Langarica Director Sony Electronic Trade Compliance 16535 Via Esprillo San Diego, CA 92127 RE: Country of Origin; USMCA; Marking; Verona Crystal LED Display Cabinet Dear Director Langarica: This is in response to your September 13, 2024 ruling request, regarding the classification, country of origin for purposes of marking and Section 301 measures, and eligibility for preferential tariff treatment under the United States-Mexico-Canada Agreement (“USMCA”) to the Verona Crystal LED Display Cabinet (“display cabinet”). You provided images and product brochures with your request. FACTS: The Sony Electronic (“Sony”) display cabinet is designed for use in cinematography, specifically for video walls used in virtual production in studio environments. Assembly of models ZRD-VP15EB, ZRD-VP23EB, ZRD-VP15EM, and ZRD-VP23EM is contemplated in Mexico. The main differences between the models are whether the display cabinets may operate with third party display controllers (Brompton or Megapixel), and pixel pitch. According to the bill of materials, USMCA originating and non-USMCA originating materials are used, and the nonoriginating materials are all classifiable outside of headings 8528 and 8540, Harmonized Tariff Schedule of the United States (HTSUS). You state that the main components of the display cabinet are: 1. Light Emitting Diode (“LED”) Modules (on the LED module block); 2. HUB and Interconnect Printed Circuit Board Assemblies (PCBAs); 3. Metal Mechanical Frame; and 4. Firmware. You state that the most expensive component of the display cabinet is the LED module block which is imported from China. Each display cabinet contains four LED module blocks. There are four different types of module blocks depending on the pixel pitch model they are intended for. Each block contains four LED modules and a PCBA which assists with signal distribution and power supply. The function of the block is to display visual content like videos, images and other forms of graphics used as background during film studio recording. The HUB is the main PCBA onto which the Receiving Card (“RC”), that is responsible for the display cabinet’s controls, is installed onto. In addition to the functions of the RC, the HUB Board is responsible for signal distribution and power supply control. The RC boards are manually mounted onto the HUB board through a complex process in Mexico that requires automated surface mount equipment and experienced engineers and technicians. There are two types of HUB boards depending on whether the display cabinet is a Brompton or Megapixel model. The metal mechanical frame, produced in China, is the support onto which the LED module blocks and all other components of the display cabinet are assembled onto. The metal mechanical frame is designed to attach to other frames to produce the video wall. At the final production site in Mexico, a five-minute final assembly operation occurs where the main HUB board including the RC, Interconnect board, Power Supply Unit, and LED blocks are installed onto the mechanical metal frame utilizing connectors, harnesses, bolts, and washers. Once the final assembly is completed, the display cabinets are subject to additional processing which includes firmware installation and calibration. The firmware installation process takes about five minutes per display cabinet, giving each LED module the required capabilities to operate within the video wall. The firmware is installed into the main control field-programmable gate array (“semiconductor chip”) on the RC in the HUB Board to form the “brains” of the display cabinet. Different firmware codes are installed depending on whether the display cabinet is a Brompton or Megapixel model. The code for the Brompton models is written in the United Kingdom, and the Megapixel models are written in the United States. ISSUES: I. What is the tariff classification for the Verona Crystal LED Display Cabinet? II. Whether the Verona Crystal LED Display Cabinet is eligible for USCMA preferential tariff treatment? III. What is the country of origin of the Verona Crystal LED Display Cabinet for marking purposes? IV. What is the country of origin of the Verona Crystal LED Display Cabinet for Section 301 Remedies purposes? 2 LAW AND ANALYSIS: I. Classification Classification under the HTSUS is made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that classification shall be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may be applied in order. Pursuant to GRI 6, classification at the subheading level uses the same rules, mutatis mutandis, as classification at the heading level. The Explanatory Notes of the Harmonized Commodity Description Coding System (“ENs”) constitute the official interpretation of the Harmonized System. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the Harmonized System and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). EN 85.28 states, in relevant parts that “[t]his heading covers monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound recording or reproducing apparatus.” The display cabinet is eo nomine classified under heading 8528 of the Harmonized Tariff Schedule (“HTSUS”) which provides for “[m]onitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound recording or reproducing apparatus.” You have stated that the display cabinet is not capable of directly connecting to an automatic data processing (ADP) machine and is not designed for use with an ADP machine. Therefore, since the display cabinet is not capable of directly operating with an ADP machine, the display cabinet is classified under subheading 8528.59, HTSUS, which provides, in relevant part, for “Other” monitors of heading 8528. II. Eligibility for Preferential Tariff Treatment under USCMA The United States-Mexico-Canada Agreement (“USMCA”) was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). GN 11 of the HTSUS implements the USMCA. GN 11(a) provides: (i) Goods that originate in the territory of Mexico, Canada or the United States (hereinafter referred to as “USMCA country” or “USMCA countries” as further defined in subdivision (l)(xxiv) of this note) under the terms of subdivision (b) of this note and regulations issued by the Secretary of the Treasury (including Uniform Regulations provided for in the USMCA), and goods enumerated in subdivision (p) of this note, when such goods are imported into the customs territory of the United States and are entered 3 under a subheading for which a rate of duty appears in the “Special” subcolumn, followed by the symbol “S” in parentheses, are eligible for such duty rate, in accordance with section 202 of the United States-Mexico-Canada Agreement Implementation Act; and… GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the app

I. Classification Classification under the HTSUS is made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that classification shall be determined first according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may be applied in order. Pursuant to GRI 6, classification at the subheading level uses the same rules, mutatis mutandis, as classification at the heading level. The Explanatory Notes of the Harmonized Commodity Description Coding System (“ENs”) constitute the official interpretation of the Harmonized System. While not legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the Harmonized System and are generally indicative of the proper interpretation of these headings. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). EN 85.28 states, in relevant parts that “[t]his heading covers monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound recording or reproducing apparatus.” The display cabinet is eo nomine classified under heading 8528 of the Harmonized Tariff Schedule (“HTSUS”) which provides for “[m]onitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound recording or reproducing apparatus.” You have stated that the display cabinet is not capable of directly connecting to an automatic data processing (ADP) machine and is not designed for use with an ADP machine. Therefore, since the display cabinet is not capable of directly operating with an ADP machine, the display cabinet is classified under subheading 8528.59, HTSUS, which provide