N323710

N323710 January 31, 2022 MAR-2 OT: RR: NC: N4:410 CATEGORY: Country of Origin Mr. Paul S. Anderson The Anderson Law Firm 111 Barclay Boulevard, Suite 206 Lincolnshire, IL 60069 RE: The country of origin of security lights Dear Mr. Anderson: This is in response to your letter dated January 14, 2022, on behalf of your client Good Earth Lighting, Inc., requesting a country of origin determination for security lights. The merchandise under consideration is identified as SE 1291 Security Light (the “SE 1291 light”). You present a manufacturing processing scenario for the country of origin determination of the SE 1291 lights. Under the scenario, there are approximately 243 separate components shown in the bill of materials. The bill of materials lists the significant elements of the finished SE 1291 light, which include 1) Lamp Head module, 2) PIR (Passive InfraRed) Head module, and 3) Canopy module. For the Lamp Head module, the major subassembly is the LED PCBA (Printed Circuit Board Assembly) module; for the PIR Head module, the major subassembly is the PIR PCBA module; and for the Canopy module, the major subassembly is the Driver Power PCBA module. The first major subassembly is the LED PCBA module. It comprises numerous components that are sourced in China and imported into Vietnam, wherein all of these components are subjected to a Surface Mount Technology (SMT) procedure. The second major subassembly is the PIR PCBA module, which is the sensor portion of the finished 1291 light. Again, numerous components are imported from China into Vietnam, and all are subjected to an SMT procedure. The same is true of the third major subassembly, the Driver Power PCBA module. Numerous discrete parts are imported from China into Vietnam and a complex SMT procedure is employed resulting in a finished Driver Power PCBA module. Specifically, the manufacturing process in Vietnam is further described as follows: LED Module, PIR Module and Driver Module Assembly Process LED Module, PIR Module and Driver Module utilize SMT assembly, which is a sophisticated technical process requiring highly skilled workers, a clean room environment and high cost machinery. STM Process Bare Printed Circuit Boards (PCB’s) are fed into the start of an SMT production line. The first step in the process is to apply a solder paste to the PCB. Solder paste is a form of solder used to make conductive joints of components onto the PCB. Solder paste is applied to the PCB by forcing the paste through a screen stencil to apply in a designated pattern where electrical components will be placed. In the next step of the process, the PCB with solder paste is fed into a high-speed pick and place machine. The pick and place machine uses high speed robotic arms to remove or “pick” the electrical components from multiple reels and “place” them in specific locations on the PCB where the solder paste has been pre applied. For the LED module in the security light fixture, these electrical components include the Main ICs, Resistors, Ceramic Capacitors, and LEDs. For the PIR module in the security light fixture, these electrical components include the Connector Socket, Capacitors, LDO IC, Resistors, Main IC, LED, PIR sensor, CDS, and Varistor. For the Driver module in the security light fixture, these electrical components include the MOS, Capacitors, Socket, Fuse, Varistor, Resistors, Transistor, Diodes, Zenor Diode and Rectifier. All of the electrical components used in these three modules are imported from China. After the PCB is populated with the required electrical components, it is fed into a reflow oven. The reflow oven slowly heats the board and solder paste to a specific temperature which will melt the solder paste and make the electrical connection between the electrical components and the PCB. Once reflow soldering is completed, the PCB containing soldered electrical components goes through an automated x-ray and optical inspection process to ensure the components are placed and soldered correctly. Wave soldering process for insert components Wave soldering is a bulk soldering process used in the manufacture of printed circuit boards. The circuit board is passed over a pan of molten solder in which a pump produces an upwelling of solder that looks like a standing wave. As the circuit board makes contact with this wave, the components become soldered to the board. Wave soldering is used for both through-hole printed circuit assemblies and surface mount. In the latter case, the components are glued onto the surface of a printed circuit board by placement equipment, before being run through the molten solder wave. Wave soldering is mainly used in soldering of through hole components. Components such as the touch button, horizontal socket, varistor, thermistor and square fuse, electrolytic capacitor and connecting wire are inserted into the fitted board and placed into the wave soldering fixture. The primary objective of flux in the wave soldering process is to clean the components that are to be soldered, principally any oxide layers that may have formed. There are two types of flux, corrosive and noncorrosive. Noncorrosive flux requires pre-cleaning and is used when low acidity is required. Corrosive flux is quick and requires little pre-cleaning but has a higher acidity. Preheating helps accelerate the soldering process and prevent thermal shock. After wave soldering, it goes through tin-filling, QC appearance inspection and testing process, and finally can be added to other large electrical components in the production line during assembly. Electroplating Process Plastic electroplating is a process in which a conductive film is first obtained on the surface of the plastic by a certain processing method (usually Electroless Plating) and then thickened by electroplating. The PIR reflector for the security light base material is ABS material. ABS is a polymer of Acrylonitrile (Acrylonitrile), Butadiene (Butadiene) and styrene (Styrene), and has a certain surface hardness, toughness, impact resistance, surface gloss, chemical corrosion resistance, easy processing and other characteristics. ABS electroplating chemically etches Butadiene in ABS to make the surface of the product show some loose pores. A layer of conductor (such as copper) is then attached to make it conductive. ABS plating is a mixture of electro-less plating and electroplating. The process goes through degreasing, coarsening, neutralization, catalysis, de-gluing, covering chemical nickel layer, covering bright copper layer, plating semi-bright nickel layer, plating chromium layer, and finally drying and packaging. Injection Molding Process Injection molding is a technical automated process, requiring sophisticated tooling. Set-up and maintenance of the tooling require engineering level support. The PIR arm is used to connect the PIR housing to the canopy. It is injection molded in-house with a 2 cavity die. Polycarbonate raw material is fed into the hopper, melted and fed through a screw feed into a 2 cavity die with a 60 second cycle time. The control knobs, PIR reflector and some small seal silicone rings are also plastic injection molded. The PIR head module housing is a Polycarbonate plastic casing with Fresnel Lens that is used to hold the PIR PCBA module. It is injection molded in-house with a 2 cavity die and also using the insert-injection technology. Insert injection molding is the process of molding or forming plastic parts around other, non-plastic parts, or inserts. The inserted component is most commonly a simple object, such as a thread or rod, but in some cases, inserts can be as complex as a battery, motor or special component. In this case, the insert is the special component - Fresnel lens. It utilizes advanced quality molding machines that are explicitly designed for the insert injection molding process. The insert molding process necessitates extremely tight tolerances to ensure the proper formation of the plastic