CBP: Last Substantial Transformation for Trimble Receiver Took Place in US
The U.S. is where the last substantial transformation occurred for Trimble's R980 Global Navigation Satellite System (GNSS) receiver, according to a CBP notice released June 20.
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Trimble had sought a final determination on the country of origin of the receiver for government procurement purposes on Feb. 3. The receiver consists of seven main components, which undergo final assembly into a chassis in Thailand, according to CBP's June 18 decision. Trimble said the main board assembly is the primary printed circuit board assembly (PCBA) and provides the essential character of the receiver.
CBP agreed with Trimble's assessment, noting that an almost identical receiver reviewed by CBP and manufactured by Trimble also had U.S. as the country of origin.
"We agree that the assembly in Thailand is a simple assembly that does not result in a substantial transformation. It primarily involves placing the PCBAs into a 'hot box' subassembly and then affixing the 'hot box,' antenna, battery, and keypad to the chassis, in contrast to the complex [surface mount technology (SMT)] performed in the United States," CBP said. "While the two Thai-origin main components are also PCBAs and are produced using SMT, they play a subsidiary role within the device. They do not undergo any programming or process any communications or navigational information which are required for the R980 GNSS Receiver to function. The U.S.-origin components are notably more complex, which is why more worker hours are required to produce the U.S.-origin components."
Any parties seeking a judicial review of this final determination must do so by July 23.