CBP Says US Is Country of Origin for Government Procurement of Electrodes

Self-adhesive cutaneous electrodes assembled in China are of U.S. origin for government procurement purposes, CBP said in a final determination notice. The ruling was in response to a request from the importer, Rhythmlink, for a final determination of the electrodes. The electrodes consist of a “sticky pad,” made of electrically conductive U.S.-origin hydrogel "laminated onto conductive plastic and fabric backing, which is attached" to a lead wire with a minuscule amount of glue, CBP said. While there is some "low-skill" assembly of the products in China, that processing is not substantially transformative, the agency said. "We find that the U.S.-origin hydrogel imparts the essential character of the self-adhesive cutaneous electrode," CBP said.