U.S. Customs and Border Protection has issued a final determination concerning the country of origin of a video surveillance and data management system that may be offered to the U.S. government.
According to CBP, the system at issue consists of a camera array and central computer system designed to conduct and manage video surveillance operations that is capable of handling up to 64 cameras per server simultaneously and can be used to power hundreds of servers within a single, centrally administered system. It comprises components from China, Taiwan, Vietnam, Malaysia, Singapore, Thailand and Costa Rica that are assembled in the U.S. to create hardware that is then combined with U.S.-origin software.
In ruling HQ H327997, CBP concludes that the imported components undergo a substantial transformation when made into the subject systems. CBP states that the major components are sourced from a variety of countries and that no single country’s operations dominate the manufacturing operations of the finished system. Further, assembly in the U.S. fully integrates the subassemblies and component parts into the complete system.
Any party-at-interest may seek judicial review of this determination by May 26.
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. For more information on BAA requirements or restrictions, please contact Mark Segrist, Mark Tallo, or Josh Rodman.
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