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CBP Identifies Country of Origin of Treadmills

Thursday, November 10, 2016
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has issued a final determination concerning the country of origin of treadmills that may be offered to the U.S. government under an undesignated government procurement contract. Any party-at-interest may seek judicial review of this determination by Dec. 12. 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.

In the first manufacturing scenario, metal components comprising the treadmills’ major subassemblies are welded and assembled in the U.S. to form the finished product, after which the treadmills are partially disassembled for shipment to U.S. customers. The second scenario is similar except that the welding and assembly occur in Taiwan before the finished treadmill is partially disassembled and sent to the U.S. customer.

In final determination HQ H262943, CBP states that the country of origin of the treadmills is the U.S. in the first scenario and Taiwan in the second. CBP explains that while nearly all the parts of the treadmills are of Chinese origin, the extent of the assembly operations is sufficiently complex and meaningful to result in a substantial transformation in both scenarios.

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