Bit of a long post, bottom line is that at some point in or after 2005, Ford Motor company was considering, or did, or wanted to do, the following:
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The Ford Customer Service Division will import used automotive parts from Canada. The exporter will be Ford Motor Company of Canada. The parts, with various countries of origin, will be removed by Ford dealerships from used vehicles that also have various countries of origin. The submission indicates that this disassembly takes place in Canada. The disassembled parts will be accumulated by the exporter and sent to a U.S. processing center for sorting and storage. Then they will be shipped to various remanufacturing suppliers for the purpose of remanufacturing, repair, refurbishment or scrapping depending on the condition of particular items. The recovered parts will be resold in the automotive aftermarket.
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The parts in question were:
- Cylinder Heads
- A/C Compressors
- Wiper Motors
- Alternators
- Steering Boxes
Now, for how I found that out:
There's someone interested in some old armrest / door pulls I have (the common ones from the mid to late 60's) and I'm going to send them (from Canada to US) using Canada post and as part of that I need to find the HS tarrif code for these things (feel free to suggest a code, I'm looking for something appropriate under section 8708). It's quite the rabbit hole, and I happen to stumble onto this letter:
rulings.cbp.gov
It's a ruling by US Customs in response to Ford about whether or not parts disassembled (removed) from cars in Canada and brought into the US would qualify for NAFTA origin regardless of the exact and likely undocumented original origin of the parts. So anyone shipping used car parts into the US would be interested in this ruling. The ruling appears to be:
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CBP finds no evidence showing that the NAFTA intended not to treat “disassembly” as a production process. The term “production” includes a broad range of economic activity. Moreover, the goals of the NAFTA include elimination of barriers to trade, facilitation of cross-border movement of goods, promotion of economic activity in North America, and protection of the environment. Thus, it is consistent with the free trade purposes of NAFTA to treat the recovery of goods by disassembly as “production” under the NAFTA rules of origin.
It is likely that the used good will be assumed to be non-originating. However, the new regulation allows the component recovered from the used good to qualify as an originating good. If the recovered component meets the Annex 401 rule applicable to that component, the recovered component will be considered to be an originating good (or material).
In this instance, the recovered components meet their respective Annex 401/GN 12(t) rules of origin and therefore, having undergone “production”, will be considered to be originating goods.
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It's not clear to me that Ford was recovering parts only from Ford vehicles for repair work done by US Ford dealers, or if these were resold to the general public somehow.
Or maybe this activity is common knowledge to some here? And it wasn't just Ford that was (is?) doing it?
--------------
The Ford Customer Service Division will import used automotive parts from Canada. The exporter will be Ford Motor Company of Canada. The parts, with various countries of origin, will be removed by Ford dealerships from used vehicles that also have various countries of origin. The submission indicates that this disassembly takes place in Canada. The disassembled parts will be accumulated by the exporter and sent to a U.S. processing center for sorting and storage. Then they will be shipped to various remanufacturing suppliers for the purpose of remanufacturing, repair, refurbishment or scrapping depending on the condition of particular items. The recovered parts will be resold in the automotive aftermarket.
---------------
The parts in question were:
- Cylinder Heads
- A/C Compressors
- Wiper Motors
- Alternators
- Steering Boxes
Now, for how I found that out:
There's someone interested in some old armrest / door pulls I have (the common ones from the mid to late 60's) and I'm going to send them (from Canada to US) using Canada post and as part of that I need to find the HS tarrif code for these things (feel free to suggest a code, I'm looking for something appropriate under section 8708). It's quite the rabbit hole, and I happen to stumble onto this letter:
CROSS Customs Rulings Online Search System
It's a ruling by US Customs in response to Ford about whether or not parts disassembled (removed) from cars in Canada and brought into the US would qualify for NAFTA origin regardless of the exact and likely undocumented original origin of the parts. So anyone shipping used car parts into the US would be interested in this ruling. The ruling appears to be:
---------------
CBP finds no evidence showing that the NAFTA intended not to treat “disassembly” as a production process. The term “production” includes a broad range of economic activity. Moreover, the goals of the NAFTA include elimination of barriers to trade, facilitation of cross-border movement of goods, promotion of economic activity in North America, and protection of the environment. Thus, it is consistent with the free trade purposes of NAFTA to treat the recovery of goods by disassembly as “production” under the NAFTA rules of origin.
It is likely that the used good will be assumed to be non-originating. However, the new regulation allows the component recovered from the used good to qualify as an originating good. If the recovered component meets the Annex 401 rule applicable to that component, the recovered component will be considered to be an originating good (or material).
In this instance, the recovered components meet their respective Annex 401/GN 12(t) rules of origin and therefore, having undergone “production”, will be considered to be originating goods.
-------------------
It's not clear to me that Ford was recovering parts only from Ford vehicles for repair work done by US Ford dealers, or if these were resold to the general public somehow.
Or maybe this activity is common knowledge to some here? And it wasn't just Ford that was (is?) doing it?
