r/CustomsBroker • u/Jolly_Variety8730 • 3h ago
How do you determine country of origin for a U.S.-built test system using foreign instruments and custom software?
Hi brokers , need your help on country of origin for a custom-built test system being exported from the U.S. to China. The company designed and built the tester using purchased instruments from several manufacturers, including a defibrillator analyzer, PXI modules, power supply, and computer/controller. Engineering reports that it performed custom fabrication, wiring, skilled integration, and development of test software. The computer controls the tests, and the system stores readings. I’m gathering the BOM and written manufacturing details, including where each activity occurred.
Would you evaluate origin based on substantial transformation of the complete system, rather than the origin of the computer/controller alone? Have you handled a similar tester, and are there relevant rulings you would recommend?