Taiwan Is Country of Origin for Lumens VC-TR60A Camera
The country of origin for the pan-tilt-zoom (PTZ) Lumens VC-TR60A Camera is Taiwan because that's where the last substantial transformation occurred, according to a Dec. 19 determination set to be published in the Federal Register on Jan. 13.
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CBP had issued the ruling, HQ H350894, at the request of Lumens Digital Optics, which had asked CBP for a determination last July of the camera's country of origin for U.S. procurement purposes.
The ruling involves a camera designed for videoconferencing in office environments. According to the ruling, the camera can combine two video images in a picture-in-picture display, and it has dual lens 12-times optical zoom, a wide-angle fix lens, artificial intelligence motion detection, and simultaneous output for high-definition multimedia interface, ethernet and universal serial bus.
According to the ruling, 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. The main printed circuit board assembly board, as well as other components, are produced in Taiwan using a complex surface mount technology (SMT) process, while a Chinese lens is joined with other components to create a lens module in Taiwan. Final assembly occurs in Taiwan.
As CBP found in past rulings, printed circuit boards (PCBs) undergo a substantial transformation into PCBAs when various components are assembled onto the board via SMT. If the device contains multiple PCBAs, CBP examines the function of the PCBA to determine the origin of the device.
In this situation, "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," CBP concluded, "the Lumens PTZ Camera is a product of Taiwan for purposes of U.S. Government procurement."