CLA-2-85:OT:RR:NC:N2:212
Dong Wook Jeong
Duck-il Industry Co., Ltd.
21-20 Segyosandan-ro
Pyeongtaek 17843
South Korea
RE: The tariff classification and country of origin of wire harnesses
Dear Dong Wook Jeong:
In your letter dated October 2, 2025, you requested a tariff classification and country of origin determination
ruling.
There are two items at issue with this request. The first is identified as the MX5 Ambient Light Wiring
Harness (MX5), part number 3050020015Z. The second is identified as the ME1 P/HDL Mood Lamp FR
Wiring Harness (ME1), part number 2MEZC44016001. The subject wiring harnesses are comprised of a
bundle of insulated conductor wires, wrapped in plastic, and terminated at various ends with terminals and
connectors. Both harnesses are specifically designed to connect a power source within a vehicle to interior
mood lighting and the lighting control board. The only difference between the two parts is the vehicle with
which they are used.
The applicable subheading for the MX5 Wiring Harness, part number 3050020015Z and the ME1 Wiring
Harness, part number 2MEZC44016001 will be 8544.30.0000, HTSUS, which provides for “Insulated
(including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric
conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed
fibers, whether or not assembled with electric conductors or fitted with connectors: Ignition wiring sets and
other wiring sets of a kind used in vehicles, aircraft or ships.” The general rate of duty will be 5 percent ad
valorem.
In your request, you describe the manufacturing process for both harnesses to be virtually identical with only
differences in where certain parts of the process occur. For the MX5 harness, various insulated wires
originate from Korea and are sent to Vietnam. In Vietnam, the wires are cut to length, with Korean
originating terminals and connectors attached onto the ends. The conductor wires are then bundled, taped,
and tested for function before they are packaged for shipment to the U.S.
For the ME1 harness, you state that the manufacturing process is the same as noted above, but takes place in
Korea. The Korean wire conductors are cut to length and the connectors and terminals, which also originate
from Korea, are added to the ends. The wires are then bundled, taped, tested for functionality, and packaged
for shipment to the U.S.
When determining the country of origin for purposes of applying current trade remedies, 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 origin of the subject harnesses, it is the opinion of this office that the wire conductor, which in
both cases originates from Korea, imparts the character of the finished harness. Further, the addition of the
connectors and terminals is simple in nature and would not render the conductors transformed into new and
different articles of commerce. Based on the information provided, the country of origin for the MX5
harness, part number 3050020015Z, and the ME1 harness, part number 2MEZC44016001, will be Korea.
Effective May 3, 2025, Presidential proclamation 10908 imposed additional tariffs on certain automobile
parts. Additional duties on automobile parts of 25 percent are reflected in Chapter 99, heading 9903.94.05,
as provided in subdivision (g) of U.S. note 33 to this subchapter. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.94.05, in addition to subheading
8544.30.0000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of South Korea will
be subject to an additional ad valorem rate of duty of 15 percent. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.33, in addition to subheading 8544.30.0000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided
for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying
duty rates are provided at https://hts.usitc.gov/.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division