CBP: China Is Country of Origin for Brother Mobile Solutions’ Instant Thermal Printers
CBP has ruled that five models of instant thermal printers produced by Brother Mobile Solutions have China as the country of origin for government procurement purposes.
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Brother had asked CBP in November 2022 whether the thermal printers undergo substantial transformation in Japan, where they’re made into final thermal printer units. The thermal printers consist of four main component groupings: (1) a print mechanism that is comprised entirely of Chinese-origin components, which are then assembled in Japan; (2) covers and chassis that are produced in China and are assembled into the printers in Japan; (3) a sensor unit consisting of five components, including a Vietnam-produced membrane switch and other components produced in China and assembled in Japan; and (4) a main printed circuit board assembly (PCBA) produced by a third-party manufacturer in Japan.
CBP used past cases as precedent in determining how to rule in this proceeding.
“As with HQ H304677, we find the present scenario is analogous to Uniroyal and Energizer Battery where the imported material did not undergo a substantial transformation,” CBP said. “While Uniroyal did not go into detail concerning the manufacture and contribution of the sole to the shoe, the decision recognized that it was the manufacture of the upper, just like the many Chinese printer components here, that provided the character to the finished article. Similarly, we find that the mechanical printing functions are imparted by the Chinese-origin components.”