CBP is revoking two rulings related to country of origin markings under NAFTA for solar panels from Japan/Mexico (see HQ H266527 issued on May 16). In NY R00721 and NY 047417, CBP ruled that the correct country of origin for marking purposes of the solar panels was “components from Japan, assembled in Mexico” or “components from Japan, manufactured in Mexico.” However, because the panels’ country of origin is Japan, they cannot be labeled as such. This is because “the country of origin of the good is the country or countries of origin of the single material that imparts the essential character to the good” pursuant to 19 C.F.R. 102.11(b). In this case, it was ruled that the country of origin of the individual solar cells was Japan, and that the solar cells make up the essential character of the product meaning the correct country of origin is Japan. However, future imports could qualify to be marked as “products of Mexico” pursuant to the NAFTA preference override if the product can meet the requirements for a NAFTA preference override, as found in 19 C.F.R. § 102.19. The full text can be found on CBP’s website here.