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U.S. Assembly Not Sufficient to Confer Origin for Video Display Cabinets, CBP Rules

Thursday, April 26, 2018
Sandler, Travis & Rosenberg Trade Report

U.S. Customs and Border Protection has issued a final determination concerning the country of origin of LED video display cabinets that may be offered to the U.S. government under an undesignated government procurement contract. Any party-at-interest may seek judicial review of these determinations by May 29. 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 items at issue receive electronic signals and convert them into images displayed via the LEDs on the face of the cabinet. They can be used on a stand-alone basis but are more commonly attached to other cabinets to create a much larger video screen, such as for the presentation of video images to large audiences.

The video display cabinets are composed of LED modules manufactured in Taiwan from two subcomponents also manufactured in Taiwan, receiving cards and cabinets manufactured in China, and printed circuit boards, hub cards, and power supplies manufactured in Taiwan. Assembly into the finished product, testing, and packaging for shipment – processes that generally require no more than a day to complete – are done in the U.S.

In ruling HQ H292849 CBP concludes that the country of origin of the assembled LED video display cabinets is Taiwan. CBP explains that all but two components are sourced from Taiwan, the individual components do not lose their separate identities as a result of the assembly process and do not undergo a change in their pre-determined uses, and the assembly process is not sufficiently complex as to amount to a substantial transformation of the imported components.

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