OT:RR:NC:N2:220
Jason Cunningham
Sonnenberg & Cunningham PA
780 Fifth Ave South
Naples, FL 34102
RE: The country of origin of electrical couplers
Dear Mr. Cunningham:
In your letter dated April 10, 2025, you requested a country of origin ruling on behalf of your client, Great
Star Tools.
There are five items under consideration that are described as crimp style electrical couplers and/or electrical
splices. The first item is referred to as the Blue Heat Shrink Butt Splice Terminal and consists of a stamped,
formed, and coated copper electrical coupler with a heat shrink plastic insulative coating. In use, electrical
wires are inserted into the ends, the connector is crimped to form an electrical connection, and heat is applied
to the insulation that shrinks around the inserted wire.
The second item is referred to as the Red Female Quick Connector and consists of a stamped, formed, and
coated copper electrical socket coupler with a plastic insulative coating. In use, an electrical wire is inserted
into the end and the connector is crimped to form a female socket electrical connection.
The third item is referred to as the Blue Male Quick Connector and consists of a stamped, formed, and coated
copper electrical socket coupler with a plastic insulative coating. In use, an electrical wire is inserted into the
end and the coupler is crimped to form a male terminal electrical connection. The Blue Male Quick
Connector blade is intended to be inserted into the Red Female Quick Connector to adjoin two electrical
wires with the capability of disconnecting and/or reconnecting.
The fourth item is referred to as the Red U-Type (Spade) Wire Connector and consists of a stamped, formed,
and coated copper electrical spade terminal with a plastic insulative coating. In use, one or more electrical
wires are inserted into the end and the coupler is crimped to form a slotted electrical connection.
The fifth item is referred to as the Blue Hole-Type (Ring) Wire Connector and consists of a stamped, formed,
and coated copper electrical ring terminal with a plastic insulative coating. In use, one or more electrical
wires are inserted into the end and the coupler is crimped to form a ring type electrical connection
In your submission, you state that all the subject couplers are constructed with raw bulk copper strip that is
produced in Korea. In Vietnam, each of the couplers are stamped into individual blanks of the proper size,
diameter, and length. Also in Vietnam, the couplers are cropped, punched, and formed into their proper
shape. The couplers are then shipped to China where they undergo spot welding, an anti-corrosive coating
process and receive their plastic insulation.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (?HQ?) H301619, dated November 6, 2018. The test for determining whether a
substantial transformation will occur is whether an article emerges from a process with a new name,
character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v.
United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See
National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff?d, 989 F.2d 1201 (Fed. Cir. 1993).
Regarding the country of origin of the five couplers, in our view, the assembly operations performed in
Vietnam, which consist of stamping, cropping, punching, and forming copper sheet into an electrical coupler
substantially transforms the Korean bulk copper strips into a new commercial article that functions as an
electrical coupler. However, it is the opinion of this office that the anti-corrosive coating and addition of a
plastic insulator does not substantially transform the electrical couplers as a result of the operations
conducted in China. ?Therefore, based upon the facts presented, the subject couplers are considered products
of Vietnam for origin purposes at time of importation into the United States.
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 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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division