The eligibility of the United States-Mexico-Canada Agreement (USMCA) of a Video Control Cabinet Insert from Mexico

N362641 July 20, 2026 OT:RR:NC:N2:206 CATEGORY: Trade Programs Mr. Arthur Bodek GDLSK 599 Lexington Ave. New York, NY 10022 RE: The eligibility of the United States-Mexico-Canada Agreement (USMCA) of a Video Control Cabinet Insert from Mexico Dear Mr. Bodek: In your letter, dated June 26, 2026, you requested a binding ruling on the eligibility of a Video Control Cabinet (VCC) Insert under the United States-Mexico-Canada Agreement (USMCA) on behalf of Panasonic Avionics Corporation. The VCC Insert is described as an aircraft cabinet housing for the aircraft entertainment system. It is a unit that is inserted into the VCC of an aircraft and is specially designed to incorporate aircraft entertainment system components. You state that because of its shape, size, electronic ports, cables, etc., it can only be used as part of an aircraft’s entertainment system. The VCC Insert is produced in Mexico from both originating and non-originating materials. The originating components include the frame itself and associated brackets, as well as some wires and other components. The non-originating materials include various plugs, pins, clamps, cables, connectors, wires, the terminal block, screws, tubes, and labels from France, Taiwan, India, China, Dominican Republic, Japan, and Czech Republic. All the materials identified in the bill of materials (BOM) supplied with your request are assembled in Mexico to make the VCC Insert. After importation, the VCC Insert will be combined with other components (e.g., the Crew Terminal, Enhanced Cell Modem (ECM), Wifi Antenna Bracket Assy, and the Cell Modem Antenna Assy). All these items are physically mounted inside the VCC Insert. The VCC Insert with its additional equipment will be installed in a commercial aircraft. The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN") 11 of the Harmonized Tariff Schedule of the United States (HTSUS) implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a "good originating in the territory of a USMCA country" only if- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials; (iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since the VCC Insert contains non-originating components, it is not considered a good wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor is it a product produced exclusively from originating materials per GN 11(b)(ii). Thus, we must determine whether the product qualifies under GN 11(b)(iii). This office determined that the VCC Insert is classified under subheadings 8807.30, HTSUS, as parts of aircrafts, based on Headquarters (HQ) rulings HQ H238494, dated June 26, 2014, and HQ 957165, dated September 17, 1993. As an initial matter, the following “Compiler’s Note” is identified in part on page 2 of the General Notes (GN) of the HTSUS (2026) (Rev. 11): COMPILER’S note: Multiple sets of changes to the Harmonized System have caused heading and subheading numbers and product coverage in some rules of origin for free trade agreements to be inconsistent with those in current tariff schedule chapters. Negotiations are required to enable agreement partners to update each text, plus domestic actions to implement agreed changes. As a result, the rules of origin provisions for certain United States free trade agreements have NOT been updated since major changes to the HTS were proclaimed. Where not updated for HS changes, be aware that the rule you try to apply may contain HTS numbers as in effect in 2002, 2007 or 2012. You can find U.S. proclamations updating rules in the Federal Register (see annexes for operative language). Changes in rules of origin reflecting HS 2022 modifications are generally not yet negotiated and proclaimed for FTAs. The new United States-Mexico-Canada Free Trade Agreement are set forth in terms of HS 2012 and may not contain current tariff numbers for some products. However, the rules for the United States-Australia Free Trade Agreement, the United States-Chile Free Trade Agreement, the United States-Bahrain Free Trade Agreement, and the United States-Korea Free Trade Agreement have been updated to reflect HS 2017, and the pertinent general notes do reflect proclaimed rectifications through 2007 or 2012, depending on the agreement. On January 26, 2022, heading 8803 was replaced by heading 8807. As a result, for goods classified under subheading 8807.30, HTSUS, we utilize the applicable rule of origin for heading 8803 under GN 11(o)/88, HTSUS, which provides: 2. A change to subheadings 8802.11 through 8803.90 from any other subheading, including another subheading within that group. Based on our review of the BOM, there are no non-originating materials classified in subheading 8807.30, HTSUS. As a result, the VCC Insert described above qualifies for USMCA preferential tariff treatment. The item will therefore be entitled to a free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and agreements. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division