U.S. Customs and Border Protection has issued a final determination concerning the country of origin of certain thermal printers that may be offered to the U.S. government. Any party-at-interest may seek judicial review of this determination by July 15.
According to CBP, the printers at issue incorporate more than 100 discrete components, 97 percent of which are imported from China, with one percent each from Taiwan, Vietnam, and Japan (the latter including the printed circuit board assembly, which the petitioner said functions as the “brains” of the printers and therefore imparts their essential character). The components are all assembled into the printers in Japan, which is also where the printers’ firmware (software embedded into the PCBA that controls the printer) is designed and developed. The petitioner indicated that slightly more than half of the printers’ value is attributable to production occurring in China and slightly less than half is produced in Japan.
In ruling HQ H328859, CBP concluded that the country of origin of the printers is China. CBP said that while the PCBA and Japanese-origin firmware enable the printers to communicate with external devices and process the images to be printed, the other components and assemblies are also critical to the printers’ function. CBP then determined that the largest portion of both cost and components used in producing the printers is imparted by the Chinese-origin components.
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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