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CBP Identifies Country of Origin of Laser Printers, Multifunction Digital Imaging Systems

Thursday, May 30, 2013
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has issued separate final determinations concerning the country of origin of certain monochrome laser printers and certain multifunctional digital imaging systems 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.

Both the laser printers and the digital imaging systems include parts made in China, Korea, Japan and the Philippines, and their entire engineering, development, design and artwork processes take place in Japan. Chinese subassemblies are imported into the U.S., where they are combined with U.S.-origin controller units and programmed with Japanese-origin firmware. CBP concludes that because the assembly in the U.S. completes the devices, the last substantial transformation occurs in the U.S., which is therefore the country of origin of the finished articles for purposes of U.S. government procurement.

These determinations were issued May 21 and any party-at-interest may seek judicial review of them by July 1.

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