U.S. Customs and Border Protection has issued a final determination concerning the country of origin of certain battery-electric semi-trucks that may be offered to the U.S. government.
According to CBP, the items at issue are battery-electric, zero emission, heavy-duty trucks designed for short-haul regional-metro applications. They are composed of 1,349 parts, including chassis made in Mexico, wiring harnesses made in Spain, axles made in Italy, and power distribution units made in Malta, but 67 percent of the total cost of the component parts is represented by U.S.-made products.
In ruling HQ H335387, CBP concludes that the imported components undergo a substantial transformation in the U.S. when assembled into the semi-truck. CBP explains that various imported components cannot independently function and operate as an electric vehicle and instead need to be assembled in the U.S. with other necessary components of U.S. origin. Furthermore, given the complexity and duration of the U.S. manufacturing process – e.g., installation, calibration, mounting, and preparation – CBP considers these operations to be more than mere assembly.
Any party-at-interest may seek judicial review of this determination by June 13.
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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