Cable Modems Assembled in Mexico From Chinese Parts Are Subject to Tariffs, Says CBP 

Cable modems that include Chinese parts but are assembled in Mexico are subject to the third tranche of 10 percent Trade Act Section 301 tariffs on Chinese imports, said Customs and Border Protection in a Nov. 27 ruling. The ruling request was submitted by Barnes Richardson lawyer Lawrence Friedman on behalf of Zoom Telephonics. CBP's analysis was on two types of modems -- those that include Wi-Fi gateways and those that don’t. All the components involved are products of China and "bulk-packed board assemblies will be shipped in separate boxes from the remainder of the components including the case components, feet, screws, and labels," CBP said. The assembly work done in Mexico doesn't constitute a "substantial transformation" of the Chinese components, CBP said. The modems are classifiable under subheading 8517.62.0010 and therefore subject to the tariffs imposed Sept. 24, it said. The modems meet the North American Free Trade Agreement’s tariff shift requirement and are a product of Mexico for marking purposes, CBP said.