Background

U.S. Customs and Border Protection has issued a final determination concerning the country of origin of the following components of a vehicle and drive tracking system that may be offered to the U.S. government under undesignated government procurement contracts.

- three telematics devices designed to transmit vehicle tracking information over long distances

- a satellite device that allows the trackers to communicate over a satellite network when cellular connectivity is lost

- a near field communication reader allowing dispatchers and managers to monitor vehicle drivers

- an NFC keyring fob used in conjunction with the reader to identify the driver operating a vehicle

In ruling HQ H309128, CBP concludes that for purposes of U.S. government procurement the country of origin of the tracking devices, the satellite device, and the NFC reader is Canada, where the primary components are manufactured or assembled and the proprietary software is developed. CBP also concluded that the country of origin of the NFC keyring fob will be where the contactless integrated circuit is manufactured (Taiwan, Thailand, or Singapore).

Any party-at-interest may seek judicial review of this determination by Jan. 8. 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.

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