CBP Finds U.S. is Country of Origin for TCE Vehicles
U.S. Customs and Border Protection has issued a final determination that the U.S. is the country of origin of the Transit Connect Electric (TCE) Vehicle 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 Azure Dynamics Corporation.
(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.)
Components from Various Countries & U.S. Are Assembled in U.S.
According to the information submitted, the TCE Vehicle is composed of 31 components, 14 of which are U.S.-origin and the remaining 17 from Turkey, Switzerland, Hungary, Japan, Germany, Canada, the United Kingdom, and various other countries.
The U.S. assembly occurs at various stations at AM General, the manufacturing subcontractor. First, a visual quality inspection of the glider is performed and the materials necessary for assembly are delivered to the proper stations. Then, holes are drilled into the glider and brackets are installed to support the battery pack and other electric assembly components. Next, a U.S.-origin battery pack, U.S. engine bay wiring harness, German power steering pump and motor, German battery coolant pump heater, and Turkish power steering lines are installed.
Four subassemblies, which previously are assembled at four substations using certain U.S. and foreign components, are also assembled and installed: cooling pack subassembly, hoses assembly, high voltage junction box assembly, and traction assembly. Various other U.S. and foreign origin parts are also installed to the vehicle.
CBP Says Imported Components Were Substantially Transformed
CBP states this assembly process is complex and time-consuming and involves a significant U.S. contribution, in both parts and labor. CBP also finds that the assembly of the U.S. and imported components was necessary for the vehicles to function, and that the assembly resulted in a substantial transformation. The glider and other components cannot function as an electric vehicle on their own. Therefore, CBP finds that the assembly of the glider and other components of various origins constitutes a substantial transformation and results in an article with a new name, character, and use, such that the country of origin for the TCE vehicle is the U.S. for purposes of U.S. Government procurement.
Any Party-at-Interest May Request Judicial Review by June 30
CBP states that any party-at-interest, as defined in 19 CFR 177.22(d), may seek judicial review of the final determination by June 30, 2011. 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 -- Barbara Kunzinger (202) 325-0359