U.S. Customs and Border Protection has issued a final determination concerning the country of origin of a satellite system receiver that may be offered to the U.S. government. Any party-at-interest may seek judicial review of this determination by July 23.
According to CBP, the item at issue is a global navigation satellite system receiver designed for surveying and mapping in challenging environments. Four of its seven main components are manufactured in the U.S., two are produced in Thailand, and one is made in Finland. Final assembly operations occur in Thailand. Two-thirds of the receiver’s proprietary software is written by developers in the U.S. and rest by developers in Germany, and the software is compiled into machine-readable binaries in the U.S.
In ruling HQ H345749 CBP concludes that the country of origin of the receiver is the U.S. because the U.S.-origin main board assembly imparts the product’s essential character, three other printed circuit board assemblies are manufactured in the U.S., and the process of programming and configuring the primary PCBA with the proprietary U.S.-origin software required for the receiver to function is done in the U.S. CBP further notes that final assembly in Thailand is a 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 or Mark Tallo.
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