CBP Determines U.S. as Country of Origin for Multifunctional Digital Imaging Systems
On May 21, CBP issued a final determination that set the U.S. as the country of origin for multifunctional digital imaging printers by Ricoh Electronics. The three different MFP models are manufactured from imported components and subassemblies from multiple countries including China and the Philippines. However, these subassemblies form incomplete and non-functional printer engines, and do not require sophisticated skills or expensive machinery. In comparison, Ricoh said development of the Controller unit, or electronic “brain”, is “extremely complex” and requires highly skilled labor to perform inspections and testing. After the Controller unit is assembled in the U.S., it is incorporated with the incomplete printer engines and the final product undergoes inspection at Ricoh’s Tustin, Calif., factory.
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Based on these facts presented, CBP ruled that the particular multifunctional digital imaging systems are assembled from parts made in China, Japan, and the Philippines, but are substantially transformed in the U.S. Pursuant to the rule of origin, CBP concluded in the final determination that the U.S. was the country of origin for purposes of government procurement.
(Federal Register 5/30/13)