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CBP Identifies Country of Origin for Toner Cartridges for Government Procurement

Tuesday, July 08, 2014
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has issued a final determination (HQ H251592) concerning the country of origin of certain all-in-one toner cartridges that may be offered to the U.S. government under an undesignated government procurement contract. This determination was issued June 24 and any party-at-interest may seek judicial review of it by Aug. 6. 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 purposes of granting waivers of certain “Buy American” restrictions in U.S. law or practice for products offered for sale to the U.S. government.

The cartridges at issue can be distinguished from conventional toner cartridges in that they contain not only the toner powder but also a cleaning unit and a development unit. The toner powder is developed and produced in Japan, the development unit is assembled in China and imported to Japan where it is filled with toner powder, and the cleaning unit is assembled in Japan of components that are all made in Japan except one part made in Thailand with parts from various countries. The toner powder, cleaning unit and development unit are brought together by the frame assembly performed in Japan.

CBP concludes that substantial manufacturing operations are performed in Japan in producing these toner cartridges and that the country of origin of the cartridges is Japan for purposes of U.S. government procurement.

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