CBP Issues Procurement Ruling on Dimmer and Fan Switches
U.S. Customs and Border Protection has issued a final determination that Mexico is the country of origin for certain dimmer and fan speed switch controls for purposes of U.S. government procurement.
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
The final determination was issued at the request of Pass & Seymour, Inc. (P&S)
(CBP issues country of origin advisory rulings and final determinations on whether an article is or would be a product of a designated country or instrumentality for the purpose of granting waivers of certain ‘‘Buy American’’ restrictions in U.S. law or practice for products offered for sale to the U.S. government.)
Switches are Assembled in Mexico from Foreign Components
The final determination concerns two P&S dimmer and fan speed control switch models: the Titan model dimmer and fan speed switch control and the Harmony dimmer.
Legrand, the French parent company of P&S, produces the subcomponents of the dimmers in Hong Kong. The subcomponents are then shipped to Mexico for assembly. The finished product is then imported into the U.S.
The processing in Mexico includes the following: (i) the assembly of the bare printed circuit board into a final printed circuit board (PCB); and (ii) the assembly of the PCB with other components into the finished product. The Titan dimmer has a total of 34 components in addition to the PCB. The Harmony dimmer contains a PCB in addition to 28 other components.
CBP Finds Substantial Transformation Occurs in Mexico
CBP finds that the assembly in Mexico is sufficiently complex and the components are
substantially transformed into a final product that has a new name, character and use.
Therefore, the country of origin of the Titan dimmer and fan switch and the Harmony dimmer for government procurement purposes is Mexico.
Any Party-at-Interest May Request Judicial Review by July 29, 2010
CBP states that any party-at-interest, as defined in 19 CFR 177.22(d), may seek judicial review of this final determination by July 29, 2010. In addition, under 19 CFR 177.31, any party-at-interest other than the party which requested this final determination may request that CBP reexamine the matter anew and issue a new final determination.
CBP contact -- Karen Greene (202) 325-0041
(FR Pub 06/29/10, HQ H098417)