U.S. Customs and Border Protection has issued a final determination concerning the country of origin of an ultrasound system that may be offered to the U.S. government. Any party-at-interest may seek judicial review of this determination by Aug. 17.
The item at issue is used to perform diagnostic ultrasound imaging by transmitting and processing sound waves to create a visual representation of a patient’s internal organs and tissues. It consists of a number of components and major subassemblies from various countries, including the U.S., Mexico, and other TAA-designated and non-TAA-designated countries.
In the first phase of assembly, which takes places in Mexico, a third-party manufacturer assembles various subcomponents to produce two subassemblies. In the second phase, which takes place in the U.S., those subassemblies are assembled with two other components (both of which are assembled in the U.S.) and another component (sourced from a TAA country) into the finished product, which is programmed with the company’s proprietary software.
In ruling HQ H346632, CBP concludes that the last substantial transformation of the system is the U.S. CBP explains that the system is capable of producing diagnostic images only after the subassemblies are assembled together and programmed in the U.S.
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 or Mark Tallo.
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