Print PDF

Practice Areas

CBP Identifies Country of Origin of Valves Used in Fuel Storage

Friday, June 28, 2013
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has issued a final determination concerning the country of origin of certain plug-type valves often used in fuel storage and disbursement that may be offered to the U.S. government under an undesignated government procurement contract. 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. This determination was issued June 14 and any party-at-interest may seek judicial review of it by July 29.

In this case, the valve body is purchased in India and imported into the U.S., and in its imported state this valve body is usable as an isolation valve. However, an automatic differential thermal relief system is fabricated and installed onto the valve in the U.S., rendering the finished article capable of being used for applications that require double isolation and bleed functionality.

CBP concludes that the number of parts assembled, including significant numbers of U.S.-origin parts, and the relative complexity of the operations carried out indicate that the imported components have undergone a substantial transformation by reason of the operations carried out in the U.S. Accordingly, the finished product will be considered a product of the U.S. for purposes of U.S. government procurement.

To get news like this in your inbox daily, subscribe to the Sandler, Travis & Rosenberg Trade Report.

Customs & International Headlines