I am in the middle of starting a business around a product that will get slammed by this. I was going to import the components and have the boards built here.("Made in the USA" labels are huge for my target market.)
Assuming I am parsing all of this correctly it will end up being better for me to have the PCBs assembled into the products in China and not create jobs in the USA.
You can't use the "Made in the USA" label like that anyway. It must be all or virtually all made in the USA. At best you could label it "Made in USA from Imported Parts" or "Assembled in USA."
My intention was that the casing and PCBs would be made in the USA. The only China sourced parts would be the PCB components.(Not finalized/assembled PCBs.) As far as I know that would qualify for "Made in the USA".
You are 100% correct in this. You can call your device just fine as made in the USA even if your passives, ICs and so on come from elsewhere. The other commenters don't understand anything about electronics.
* PCB (Milled, Drilled, Components Soldered) - USA Origin
* Connectors - USA Origin
* Firmware - USA Origin
* PCB Components (Items affected by the tariffs) - China or Otherwise
As far as I know that would qualify as "Made in the USA" or at the minimum "Assembled in the USA". Over 75% of the components have USA origins and the final transformative step is done in the USA.
Please note that I am not trying to be deceptive in my future product's labeling.(6+ months until launch.) However, with political changes like these tariffs they are something that can basically change my stance on how I decide to source in the USA.
Who wrote that horrible document? How exactly does someone determine whether "All or virtually all" is applicable in their situation without specific values. Sure there are examples, but they are not exhaustive.
In Canada the definitions are simple and clear:
A "Product of Canada" must have its final transformation done in Canada, and at least 98% of the costs are incurred in Canada
Something "Made in Canada" is as above, except the value is 51% and includes a statement about whether imported parts were used.
Wait, a second... Do you really know this? Have your supplier prices already increased? By how much on average of each imported component? What's the total increase per unit shipped?
Yeah, I'm worried because a nonprofit I'm working for recently decided to manufacture a convention badge in Ohio rather than China because it was barely economically feasible... with this tariff change it may eat too far into our donations.
Just an aside, I used to work at a custom label printing place (in Ohio even, funny that), which often got convention orders because they had holograms on them.
I think security around conventions can be concern (you don't want someone doctoring a phony badge and walking into a convention with a few thousand people.
Sorry to hear you're getting hit by this! I wrote the Verge piece, and would love to talk to you about how this is affecting your business plans. Drop me a line at russell@theverge.com.
Are we to infer that BOM is the big cost for you, even though you're doing all the manufacture in USA? That seems unlikely to me, based on what I've heard about electronics manufacturing.
Assuming I am parsing all of this correctly it will end up being better for me to have the PCBs assembled into the products in China and not create jobs in the USA.