Notice2026-00484
Notice of Issuance of Final Determination Concerning Lumens VC-TR60A Camera
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Metadata and text below are from the Federal Register, a public-domain U.S. government work. Always verify the official published version before relying on it for any legal matter.
Published
January 13, 2026
Issuing agencies
Homeland Security DepartmentU.S. Customs and Border Protection
Abstract
This document provides notice that U.S. Customs and Border Protection (CBP) has issued a final determination concerning the country of origin of the Lumens VC-TR60A Camera. Based upon the facts presented, CBP has concluded that the last substantial transformation of the Lumens VC-TR60A Camera occurs in Taiwan.
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<title>Federal Register, Volume 91 Issue 8 (Tuesday, January 13, 2026)</title>
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[Federal Register Volume 91, Number 8 (Tuesday, January 13, 2026)]
[Notices]
[Pages 1327-1329]
From the Federal Register Online via the Government Publishing Office [<a href="http://www.gpo.gov">www.gpo.gov</a>]
[FR Doc No: 2026-00484]
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DEPARTMENT OF HOMELAND SECURITY
U.S. Customs and Border Protection
Notice of Issuance of Final Determination Concerning Lumens VC-
TR60A Camera
AGENCY: U.S. Customs and Border Protection, Department of Homeland
Security.
ACTION: Notice of final determination.
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SUMMARY: This document provides notice that U.S. Customs and Border
Protection (CBP) has issued a final determination concerning the
country of origin of the Lumens VC-TR60A Camera. Based upon the facts
presented, CBP has concluded that the last substantial transformation
of the Lumens VC-TR60A Camera occurs in Taiwan.
DATES: The final determination was issued on December 19, 2025. A copy
of the final determination is attached. Any party-at-interest, as
defined in 19 CFR 177.22(d), may seek judicial review of this final
determination no later than February 12, 2026.
FOR FURTHER INFORMATION CONTACT: Anna Hedstrom, Valuation and Special
Programs Branch, Regulations and Rulings, Office of Trade, at (202)
325-0227.
SUPPLEMENTARY INFORMATION: Notice is hereby given that on December 19,
2025, CBP issued a final determination concerning the country of origin
of the Lumens VC-TR60A Camera for purposes of Title III of the Trade
Agreements Act of 1979. This final determination, Headquarters Ruling
Letter (HQ) H350894, was issued at the request of Lumens Digital
Optics, Inc. under procedures set forth at 19 CFR part 177, subpart B,
which implements Title III of the Trade Agreements Act of 1979, as
amended (19 U.S.C. 2511-18). In the final determination, CBP has
concluded that the last substantial transformation of the Lumens VC-
TR60A Camera occurs in Taiwan.
Section 177.29, CBP Regulations (19 CFR 177.29), provides that a
notice of final determination shall be published in the Federal
Register within 60 days of the date the final determination is issued.
Section 177.30, CBP Regulations (19 CFR 177.30), provides that any
party-at-interest, as defined in 19 CFR 177.22(d), may seek judicial
review of a final determination within 30 days of publication of such
determination in the Federal Register.
Alice A. Kipel,
Executive Director, Regulations and Rulings, Office of Trade.
[GRAPHIC] [TIFF OMITTED] TN13JA26.011
HQ H350894
December 19, 2025
OT:RR:CTF:VS H350894 ACH
CATEGORY: Origin
Gary Zheng, Lumens Digital Optics, Inc., 5F No. 20 Taiyung Street,
Jhubei, 301 Taiwan
RE: U.S. Government Procurement; Title III, Trade Agreements Act of
1979 (19 U.S.C. 2511); Subpart B, Part 177, CBP Regulations; Country of
Origin of Lumens Camera
Dear Mr. Zheng,
This is in response to your July 8, 2025 request for a final
determination concerning the country of origin of the Pan Tilt Zoom
(``PTZ'') Lumens VC-TR60A Camera (``Camera'') pursuant to Title III of
the Trade Agreements Act of 1979 (``TAA''), as amended (19 U.S.C. 2511
et seq.), and subpart B of Part 177, U.S. Customs and Border Protection
(``CBP'') Regulations (19 CFR 177.21, et seq.). Lumens is a party-at-
interest within the meaning of 19 CFR 177.22(d)(1) and 177.23(a) and is
therefore entitled to request this final determination.
Facts
The merchandise under consideration is the Lumens PTZ Camera, Model
Number TR60A. This camera is designed for video conferencing in office
environments. It features speaker tracking that allows the camera to
move toward the person speaking during a discussion. The camera also
can combine two video images in a picture-in-picture display, providing
both a wide-angle view and a close-up shot of the meeting.
Additionally, it has a dual lens 12 times optical zoom, wide-angle fix
lens, Artificial Intelligence (``AI'') motion detection, and
simultaneous output for High-Definition Multimedia Interface
(``HDMI''), Ethernet, and Universal Serial Bus (``USB'').
The camera production consists of nine main steps: (1) zoom lens
module assembly and calibration; (2) PTZ camera body assembly; (3)
panoramic lens module assembly; (4) zoom lens and panoramic lens
optical axis alignment; (5) run in test; (6) firmware programming to
camera; (7) system function test; (8) quality control inspection; and
(9) final packaging and shipping. One camera takes around three hours
to produce.
The camera's initial source code, which includes requirements for
the graphical user interface that provides product status information
and the user operation interface, is developed in China and sent to
Taiwan for burning. This software has been developed over a year and a
half and has undergone
[[Page 1328]]
multiple updates. The ultimate consumer is unable to customize or
remove the software.
The printed circuit boards (``PCB''), electronic components,
optical parts, and mechanical parts of the camera are sourced from
global suppliers (including regions outside TAA countries). The camera
includes seven printed circuit board assemblies (``PCBAs''): the main
board (claimed to be the brains of the camera), driver board, power
over Ethernet (``POE'') board, home sensor board, panoramic sensor
board, zoom lens sensor board, and microphone board. The bare PCB and
PCBA components (e.g., resistors, capacitors, diodes, etc.) are sourced
through third parties in China.
It is stated that two components fulfill the image conversion and
capture function: the sensors and the image signal processor. The
sensors are responsible for light conversion, and the image signal
processor is responsible for transferring the sensor data into visible
images through digital signal processing. These two components are
included on the zoom lens sensor board, panoramic sensor board, and
main board.
In Taiwan, the main PCBA board, the panoramic sensor board, the POE
board, the zoom lens sensor board, the driver board, and the home
sensor board are produced through a complex surface mount technology
(``SMT'') process, which results in fully functional PCBAs. Of all of
the PCBA components that are used to make the various boards, around
72% of them are used to make the main PCBA board. The SMT process
involves solder paste printing component placement, reflow soldering,
inspection, and testing. Additionally, a Chinese lens is joined with
other components to create a lens module in Taiwan. The final assembly
process operations, firmware programming, calibration, function
testing, quality control inspection, packaging, and shipping also occur
in Taiwan. In China, the microphone board is manufactured. No other
manufacturing takes place in China.
The longest production process is the zoom lens module pre-
processing, processing, and assembly which takes approximately 44% of
the camera's production time, longer than any other steps. This process
includes integrating the zoom lens, sensor board, and driver board,
calibration, integration, adjustment of parts, mounting, and enclosing
the module. This production is said to take place in Taiwan.
Issue
What is the country of origin of the Lumens Camera for the purposes
of U.S. Government procurement?
Law and Analysis
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 purpose of granting
waivers of certain ``Buy American'' restrictions in U.S. law or
practice for products offered for sale to the U.S. Government, pursuant
to subpart B of Part 177, 19 CFR 177.21-177.31, which implements Title
III of the TAA, as amended (19 U.S.C. 2511-2518).
CBP's authority to issue advisory rulings and final determinations
stems from 19 U.S.C. 2515(b)(1), which states:
For the purposes of this subchapter, the Secretary of the
Treasury shall provide for the prompt issuance of advisory rulings
and final determinations on whether, under section 2518(4)(B) of
this title, an article is or would be a product of a foreign country
or instrumentality designated pursuant to section 2511(b) of this
title.
Emphasis added.
The Secretary of the Treasury's authority mentioned above, along
with other customs revenue functions, are delegated to the Secretary of
Homeland Security via Treasury Department Order (``TO'') 100-20
``Delegation of Customs revenue functions to Homeland Security,'' dated
October 30, 2024, and are subject to further delegations to CBP (see
also 19 CFR part 177, subpart B).
The rule of origin set forth under 19 U.S.C. 2518(4)(B) states:
An article is a product of a country or instrumentality only if
(i) it is wholly the growth, product, or manufacture of that country
or instrumentality, or (ii) in the case of an article which consists
in whole or in part of materials from another country or
instrumentality, it has been substantially transformed into a new
and different article of commerce with a name, character, or use
distinct from that of the article or articles from which it was so
transformed.
See also 19 CFR 177.22(a).
In rendering advisory rulings and final determinations for purposes
of U.S. Government procurement, CBP applies the provisions of subpart B
of Part 177 consistent with the Federal Procurement Regulation
(``FAR''). See 19 CFR 177.21. In this regard, CBP recognizes that the
FAR restricts the U.S. Government's purchase of products to U.S.-made
or designated country end products for acquisitions subject to the TAA.
See 48 CFR 25.403(c)(1).
The FAR, 48 CFR 25.003, defines ``U.S.-made end product'' as:
. . . an article that is mined, produced, or manufactured in the
United States or that is substantially transformed in the United
States into a new and different article of commerce with a name,
character, or use distinct from that of the article or articles from
which it was transformed.
To determine whether a substantial transformation occurs when
components of various origins are assembled into completed products,
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, extent of the processing that occurs within a
country, and whether such processing renders a product with a new name,
character, and 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 will be considered when determining whether a
substantial transformation has occurred. No one factor is
determinative. See, e.g., Headquarters Ruling Letter (``HQ'') H311606,
dated June 16, 2021; and HQ H302801, dated October 3, 2019.
Energizer Battery, Inc. v. United States, 190 F. Supp. 3d 1308 (Ct.
Int'l Trade 2016), involved manufacture of a flashlight in which all
the components of the flashlight were of Chinese origin, except for a
white LED and a hydrogen getter. The components were imported into the
United States and assembled into the finished Generation II flashlight.
The Energizer Battery court applied the ``name, character and use''
test to determine whether a substantial transformation had occurred and
noted, citing Uniroyal, Inc. v. United States, 542 F. Supp. 1026, 1031
(Ct. Int'l Trade 1982), that when ``the post-importation processing
consists of assembly, courts have been reluctant to find a change in
character, particularly when the imported articles do not undergo a
physical change.'' Energizer Battery at 1318. In addition, the court
noted that ``when the end-use was pre-determined at the time of
importation, courts have generally not found a change in use.''
Energizer Battery at 1319, citing as an example, National Hand Tool
Corp. v. United States, 16 C.I.T. 308, 312 (1992), aff'd, 989 F.2d 1201
(Fed. Cir. 1993). Further, courts have considered the nature of the
assembly, i.e., whether it is a simple or complex assembly, such that
individual parts lose their separate identities and become integral
parts of a new article. Energizer Battery, 190 F. Supp. 3d 1308.
[[Page 1329]]
Regarding electronic equipment, CBP has found that circuit boards
undergo a substantial transformation into PCBAs when various components
are assembled onto the board via SMT. See C.S.D. 85-25, 19 Cust. Bull.
844 (1985) (determining that the assembly of the PCBA involved a very
large number of components and a significant number of different
operations, required a relatively significant period of time as well as
skill, attention to detail, and quality control, and resulted in
significant economic benefit to the beneficiary developing country from
the standpoint of both value added to the PCBA and the overall
employment generated thereby). Additionally, CBP has found that the
mere attachment of wires to a PCBA and installation into a case, along
with minor tuning processes, does not result in a substantial
transformation. See HQ 561232, dated April 20, 2004.
In rulings concerning the country of origin of origin of a device
containing multiple PCBAs, CBP has examined the function of the PCBAs
contained in the device to determine the origin of the device. See HQ
H311606, dated June 16, 2021. In New York Ruling Letter (``NY'')
N348165, dated May 12, 2025, CBP found the country of origin of a
camera to be the country in which the PCBA became fully functional. In
multiple rulings, CBP determined that the PCBAs contributed to the main
functionality of a finished camera. In NY N339727, dated May 21, 2024,
CBP stated that the PCBAs contributed to the main functionality of
security cameras and that there was no substantial transformation after
the PCBAs were constructed. In NY N330296, dated February 8, 2023, and
NY N328151, dated October 6, 2022, CBP stated that the PCBAs for a
surveillance camera contributed to the main functionality of the
camera.
Here, the zoom sensor board, panoramic sensor board, and main board
are essential to the character of the finished camera as they are
responsible for capturing and converting images. These boards enable
the camera to function as intended. These boards are produced in
Taiwan. Additionally, the zoom lens assembly, which is the longest and
most complex assembly process, takes place in Taiwan. Therefore, the
Lumens PTZ Camera is a product of Taiwan for purposes of U.S.
Government procurement.
Holding
Based on the information provided, for purposes of U.S. Government
procurement, the Lumens PTZ Camera is a product of Taiwan.
Notice of this final determination will be given in the Federal
Register, as required by 19 CFR 177.29. Any party-at-interest other
than the party which requested this final determination may request,
pursuant to 19 CFR 177.31, that CBP reexamine the matter anew and issue
a new final determination. Pursuant to 19 CFR 177.30, any party-at-
interest may, within 30 days of publication of the Federal Register
Notice referenced above, seek judicial review of this final
determination before the U.S. Court of International Trade.
Sincerely,
Alice A. Kipel,
Executive Director, Regulations and Rulings, Office of Trade.
[FR Doc. 2026-00484 Filed 1-12-26; 8:45 am]
BILLING CODE 9111-14-P
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</html>Indexed from Federal Register on January 13, 2026.
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