Print PDF

Practice Areas

CBP Identifies Country of Origin for Billiards Tables

Wednesday, October 21, 2015
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has issued a final determination concerning the country of origin of certain billiards tables that may be offered to the U.S. government under an undesignated government procurement contract. This determination was issued Oct. 15 and any party-at-interest may seek judicial review of it by Nov. 20. 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 tables at issue are designed and developed in the U.S. and each is produced in the U.S. from components and subassemblies sourced from various countries, including the U.S. Due to the size and weight of each table, the company ships the individual components (ranging in number from 71 to 91) to the U.S. customers’ locations and assembles the tables onsite. The assembly and installation must be performed by certified company installers who are employed and extensively trained by licensed U.S.-based company dealers.  

CBP finds that the assembly processes that occur in the U.S. are complex and meaningful, require the assembly of a large number of components, and render a new and distinct article of commerce that possesses a new name, character and use. While not dispositive, CBP also notes that the engineering, design and development of the tables occur in the U.S. Accordingly, the assembled billiards tables will be considered products 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