CBP Determines Trimble's GNSS Receiver Is a US Product
The Global Navigation Satellite System (GNSS) R12i Receiver produced by industrial technology company Trimble is a U.S. product for government procurement purposes, even though its final assembly occurs in Thailand, CBP said in a notice of final determination released June 4.
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The GNSS R12i Receiver also is exempt from the country of origin marking requirements of 19 CFR 134.32(m), the agency said.
Trimble, a Delaware corporation headquartered in Westminster, Colorado, that specializes in the production and design of industrial technology for the agricultural, construction and geospatial transportation industries, asked CBP March 1 to issue a final determination on the receiver’s country of origin, pursuant to Title III of the Trade Agreements Act of 1979.
The company had sought to confirm the country of origin for the receiver for U.S. government procurement purposes.
According to Trimble, the receiver has seven primary components, which undergo final assembly into a chassis in Thailand: a main board assembly, power supply and communications board assembly, antenna element assembly, radio interface, antenna low-noise amplifier, battery SIM and 450MHz radio.
The first four of those components are manufactured in the U.S., according to Trimble, with three of these components considered as printed circuit board assemblies (PCBAs). The main board assembly also provides the essential character of the receiver, CBP said. The antenna low-noise amplifier and the battery SIM are produced in Thailand while the 450MHz radio is made in China.
Although some components were manufactured in other countries, the more complicated components are manufactured and assembled in the U.S., CBP found, saying “the assembly in Thailand is simple assembly that does not result in a substantial transformation.”
“The U.S. origin components are notably more complex, which is why more worker hours are required to produce the U.S.-origin components than all Thailand operations combined,” CBP ruled. “Therefore, based on the totality of the circumstances, we determine that the final assembly in Thailand does not result in a substantial transformation.”