H346536

H346536 ACH CATEGORY: Origin Lisa Murrin Expeditors Tradewin, LLC 795 Jubilee Drive Peabody, MA 01960 RE: Country of origin of a 3D Printer Dear Ms. Murrin, This is in response to your ruling request dated March 11, 2025 , submitted on behalf of your client, SprintRay Inc. (“SprintRay”). You request a ruling regarding the country of origin of a 3D Printer for the purpose of determining the applicability of measures imposed under Section 301(b) of the Trade Act of 1974 (“Section 301”). FACTS: The SprintRay Midas 3D printer is a digital press stereolithography-based (DPS), dental 3D printer enabling the chairside fabrication of crowns, inlays, onlays, and veneers using photopolymer for dental professionals. It features a digital press mechanism (consisting of a print arm, two linear guides, and a stepper motor with a lead screw), a 385 nm UV-A light engine, and a front panel containing a barcode scanner and a digital dashboard/command center. The Midas 3D printer operates on the same fundamental principles as a stereolithography (SLA) printer, including digital light processing and masked-SLA technologies. The printer utilizes a light engine to cure photopolymer resin with ultraviolet light, constructing parts layer by layer with the assistance of a linear stage. What differentiates the DPS printer from traditional SLA printers is its method of resin storage. In the DPS printer, the resin is contained within a specialized capsule, which houses the liquid photopolymer and low separation surface which enables the use of a highly viscous photopolymer, rather than a conventional vat. The Midas 3D printer’s hardware and OS software are designed and developed in the United States. This software is stated to be fundamental to the functionality of the printer, transforming its hardware into a fully operational 3D printing system. All key aspects of the software, including the theory of operation, software architecture, software quality assurance, quality control, software release management, and ecosystem integration, are developed and implemented within the United States. Software and firmware developed in the U.S. are programmed to the motherboard in Mexico. Seventy percent of the software’s code was developed in-house, representing a substantial effort of 74,880 hours and a $4.32 million investment. The Midas 3D printer also uses an AI algorithm developed in the U.S. to convert patient scans into printable medical appliances. The printer is composed of a chassis, an enclosure, a light source (composed of an optical machine and its base, functioning as a 385 nm UV-A light engine), a print arm, electrical components, fasteners, and an upper chassis. The light source initiates the photopolymerization process by triggering a chemical reaction in the liquid photopolymer (a liquid chemical that undergoes a controlled chemical reaction when exposed to the light source, converting it from a liquid state to a solid), causing it to harden and form solid parts. Both components of the light source are of Chinese origin, and the light source makes up approximately 44 percent of the total components cost. The Midas 3D printer also features a high-precision light mask capable of achieving a resolution of 0.045 mm. This technology enables precise, personalized dental care by transforming raw scan data into ready-to-print models. The chassis consists of a main frame, motherboard bracket, two housing brackets, a bottom sealing plate, four fixed heightening columns, two heightening columns, and one heat sink. The enclosure consists of one bottom cover, a front panel, a rear package board, an LCD bracket, a cartridge limit block, an antenna bracket, a button fixing block, two heightening columns, four floor mats, a screw fixing module, pins, couplings, and gaskets. The light source consists of an optical machine base and an optical machine. The print arm consists of a print arm, a screw nut mounting bracket, two linear guides (which work in conjunction with the light mask to ensure precision and control in shaping the printed object), a ball screw, a photoelectric shield, a motor mounting bracket, and a screw fixing seat. The electrical components include a fan, an antenna, a touch screen assembly, a stepper motor, an optical machine control line, a core board, a motherboard (PCBA), cables, wire, and harnesses. The fasteners include approximately 164 components, such as nuts, screws, spring washers, gaskets, and tapes. The motherboard enables connectivity with digital systems. It integrates with Rayware on Cloud, which, when paired with an Intraoral Scanner, facilitates the transfer of 3D scans directly to the printer. The motherboard contains 688 electronic components, including diodes, transistors, capacitors, and memory chips, and is assembled in Mexico using surface mount technology (SMT). The components within the motherboard control the UV LED, cooling fans, motors, and sensors. The upper chassis consists of a pallet frame, a piece of glass, a glass frame, a position detection bracket, and a pallet support. All the components of the Midas 3D printer are made in China except the PCBA (Mexico), lubricating oil (Japan), AB glue (United States), linear guides (Taiwan), and ball screw (Japan). These components are fully assembled into the finished product in Mexico by trained workers utilizing specialized tools taking approximately two hours. Production in Mexico includes quality control inspections, assembly, installation, motherboard production and programming, calibration, testing, inspection, and packaging. Technicians assembling the printer undergo 300 hours of specialized training. Quality control processes include advanced X-ray and Automated Optical Inspection technologies. ISSUE: What is the country of origin of the 3D printer for purposes of the application of Section 301 trade remedy duties? LAW AND ANALYSIS: The United States Trade Representative (“USTR”) has determined that an additional duties will be imposed on certain Chinese imports pursuant to its authority under Section 301. The Section 301 measures apply to products of China enumerated in Section XXII, Chapter 99, Subchapter III, U.S. Note 20(e) and (f), HTSUS. When determining the country of origin for purposes of applying the Section 301 measures, the substantial transformation analysis is applicable. The test 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. Texas Instruments, Inc. v. United States, 69 CCPA 151, 681 F.2d 778 (1982). U.S. Customs and Border Protection (“CBP”) considers the totality of the circumstances and makes substantial transformation determinations on a case-by-case basis. CBP has stated that a new and different article of commerce is an article that has undergone a change in commercial designation or identity, fundamental character, or commercial use. A determinative issue is the extent of the operations performed and whether the materials lose their identity and become an integral part of the new article. See Nat’l Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In order to determine whether a substantial transformation occurs, CBP considers the totality of the circumstances and makes such determinations on a case-by-case basis. The country of origin of the item’s components, the extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, or use are primary considerations in such cases. Additionally, factors such as the resources expended on product design and development, the extent and nature of post-assembly inspection and testing procedures, and worker skill required during the actual manufacturing process may be considered when determining whether a substantial transformation has occurred. No one factor is determinative. See e.g., Headquarters Ruling Letter (“HQ”) 

The United States Trade Representative (“USTR”) has determined that an additional duties will be imposed on certain Chinese imports pursuant to its authority under Section 301. The Section 301 measures apply to products of China enumerated in Section XXII, Chapter 99, Subchapter III, U.S. Note 20(e) and (f), HTSUS. When determining the country of origin for purposes of applying the Section 301 measures, the substantial transformation analysis is applicable. The test 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. Texas Instruments, Inc. v. United States, 69 CCPA 151, 681 F.2d 778 (1982). U.S. Customs and Border Protection (“CBP”) considers the totality of the circumstances and makes substantial transformation determinations on a case-by-case basis. CBP has stated that a new and different article of commerce is an article that has undergone a change in commercial designation or identity, fundamental character, or commercial use. A determinative issue is the extent of the operations performed and whether the materials lose their identity and become an integral part of the new article. See Nat’l Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). In order to determine whether a substantial transformation occurs, CBP considers the totality of the circumstances and makes such determinations on a case-by-case basis. The country of origin of the item’s components, the extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, or use are primary considerations in such cases. Additionally, factors such as the resources expended on product design and development, the extent and nature of post-assembly inspection and testing procedures, and worker skill required during the actual manufacturing process may be considered when determining whether a substantial transformat