CBP Determines the U.S. as Country of Origin for Laser Printers
CBP issued a notice of final determination on May 21 for the country of origin of Ricoh Aficio Monochrome Laser Printers for purposes of procurement by the U.S. government under Federal Acquisition Regulations. CBP said it reached this final determination based on presented facts, which indicated that the monochrome laser printers were assembled from parts made in China, Japan, and the Philippines, but was assembled and substantially transformed in the U.S. The manufacture of individual parts (subassemblies), such as the duplex unit and engine board, took place in other countries during initial stages of the production process. However, these basic subassemblies only resulted in an “incomplete and non-functional printer engine” and did not require “sophisticated skills or expensive machinery.”
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Subassembly of the Controller unit, the printer’s electronic “brain”, takes place at Ricoh’s factory in Tustin, Calif., and is an extremely complex process that requires skilled labor and millions of invested dollars. This vital unit is incorporated into the incomplete, non-functional printer engines to create a functioning, final product, which undergoes inspection at the Tustin factory. Pursuant to Federal Acquisition Regulations, the CBP thus determined that the monochrome printers were “substantially transformed in the United States into a new and different article of commerce” as a result of the assembly and firmware installation operations performed in the U.S.
(Federal Register 05/30/13)