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Initial Loading of Critical Software May Not Always Define Country of Origin

Client Alert | 1 min read | 04.10.13

On April 3, 2013, the Bureau of Customs and Border Protection (CBP) issued two final determinations on the country of origin for complex electronic equipment which demonstrate the role that loading of U.S.-origin system software or firmware can play in identifying the country of origin under the substantial transformation test applicable to the Trade Agreements Act. In Country of Origin of Ultrasound Systems (a matter handled by Crowell & Moring), CBP concluded that the country of origin was the U.S. despite an initial system software load to the electronics module in China, when complex components from multiple countries subsequently were combined in the U.S. along with the download of the final system software, whereas in Country of Origin of HP LaserJet Enterprise 500 Color M551 Printer and Fax Machine, CBP concluded that loading U.S.-origin firmware along with a simple (7-minute) final assembly operation in Mexico did not substantially transform the complex LaserJet printer components and subassemblies manufactured in China, resulting in China being the country of origin.


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Client Alert | 3 min read | 02.27.26

EEOC v. Coca-Cola Beverages Northeast, Inc.: Another Step Focused on the EEOC’s Goal of Eradicating Unlawful DEI-Related Practices

On February 17, 2026, the U.S. Equal Employment Opportunity Commission (EEOC) filed a complaint against Coca-Cola Beverages Northeast, Inc., in the United States District Court for the District of New Hampshire, alleging that the company violated Title VII of the Civil Rights Act of 1964 (Title VII) by conducting an event limited to female employees. The EEOC’s lawsuit is one of several recent actions from the EEOC in furtherance of its efforts to end what it refers to as “unlawful DEI-motivated race and sex discrimination.” See EEOC and Justice Department Warn Against Unlawful DEI-Related Discrimination | U.S. Equal Employment Opportunity Commission....

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