OT:RR:NC:N2:212
Deborah Stern
Sandler, Travis & Rosenberg, P.A.
5835 Waterford District Drive, Suite 200
Miami, FL 33126
RE: The country of origin of USB cables
Dear Ms. Stern:
In your letter dated July 1, 2025, you requested a country of origin ruling on behalf of your client, Belden
Inc.
There are two items at issue with this request, which are identified by part numbers SK-BV-3692 and
SK-BV-3906 and are described as USB cables. The subject cables are constructed of four copper core
conductors and a single drain wire, which are twisted together and wrapped in braiding, jacketing, and
insulation. The cables are imported on reels and not terminated with connectors on either end. The subject
cables are identical and are used to charge devices, transfer data, and connect various electronic devices.
In your request, you state that the manufacturing process begins in Thailand with the creation of the copper
conducting cores. Each core is manufactured by winding multiple individual copper wires, of Thai origin,
together. The cores are then sent to China, where each core is wrapped with an insulating adhesive. Two of
these cores are then mechanically twisted together to form a twisted pair and shipped to India, along with two
other insulated cores, which are not twisted together. In India, the twisted pair and two untwisted insulated
cores are wrapped with mylar tape and tinned-copper braiding to create a shield. The cable is then jacketed
with insulation before the finished cable is tested and prepared for shipment to the United States.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling
Letter 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 origin of the subject cables, it is the opinion of this office that the four copper cores, which are
stranded and wound in Thailand, impart the character of the finished cable as they are the primary electrical
conducting component. The various steps performed in both China and India do not substantially transform
the cores into new and different articles of commerce. Based upon the facts presented, the country of origin
of the USB cables, part numbers SK-BV-3692 and SK-BV-3906, will be Thailand.
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 Luke LePage at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division