U.S. Customs and Border Protection has issued a final determination concerning the country of origin of certain global navigation satellite system receivers that may be offered to the U.S. government. Any party-at-interest may seek judicial review of this determination by July 10.
According to CBP, the items at issue consist of seven primary components assembled into a chassis in Thailand. Four of these components are manufactured in the U.S., including three characterized as printed circuit board assemblies. Two components, which the petitioner asserts perform subsidiary roles, are produced in Thailand, while one component characterized as optional is produced in China.
In ruling HQ H338116, CBP concludes that the country of origin of the finished receivers is the U.S. because the primary PCBA provides their essential character and originates in the U.S. where most of the required production takes place, including programming and configuring with proprietary U.S.-origin software required for the device to function. Further, CBP states, assembly in Thailand is simple assembly that does not result in a substantial transformation.
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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