CBP Finds Dishwasher Pump Assembly Results in Substantial Transformation

Dishwasher pumps made of parts from China that are assembled in Serbia are considered to be of Serbian origin, CBP said in a Jan. 23 ruling. Due to the Serbian origin of the pumps, Section 301 tariffs on goods from China do not apply, CBP said. The ruling came in response to a request from Thomas Keating, of Rock Trade Law, on behalf of Johnson Electric North America.

The pumps include a pump assembly and an electric motor, which are combined in Serbia to from the full pump, CBP said. “The majority of the discrete parts are sourced from China, although a small percentage are sourced from Serbia and other countries,” it said. CBP has previously ruled that whether a substantial transformation has occurred can depend on “whether an assembly process is sufficiently complex.”

The dishwasher pumps assembly meets that complexity requirement, CBP found. “Approximately 50 discrete parts from China are shipped to Serbia to be manufactured into subassemblies, and then combined to form the finished centrifugal dishwasher pump,” it said. “The assembly is complex and involves soldering, fusing, machining, knurling and crimping. Therefore, we find that the discrete parts are substantially transformed when they are combined to form a finished centrifugal pump in Serbia.”