OT:RR:NC:N2:212
Alexander Morton
Chogori Technologies Inc
2915 Ogletown
Newark, DE 19713
RE: The country of origin of cable assemblies
Dear Mr. Morton:
In your letter dated November 24, 2025, you requested a country of origin ruling.
There are four items at issue with this request that are described as electrical cable assemblies and
individually identified by part numbers HRN-GA2CARGIG, HRN-GA2EXTPWR, HRN-GA2NATRL, and
HRN-GA23WIRE. The subject cable assemblies are comprised of multiple cable conducting cores, ranging
from 2 to 4 individual cores depending on the part number, that are twisted together, shielded and insulated.
At one end of the cables is a 5 or 6-pin connector. The cable assemblies are used to deliver electrical and
communications signals within a vehicle telematics system.
In your request, you state that the manufacturing process for the four parts is identical. The process begins in
Taiwan where the copper conductor is created by stranding and twisting the individual copper wire into the
appropriate configuration. The conductors are further extruded with insulation, shielded and jacketed before
they are cut to length and sent to China. In China, the ends of the cable are stripped and the connector is
assembled onto the end. The finished cable is then inspected and packaged 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 cable assemblies, it is the opinion of this office that the insulated copper
conducting core imparts the character of the finished articles. Further, the addition of the connectors in China
is not significantly complex in order to substantially transform the conductor. As such, the country of origin
of the cable assemblies, part numbers HRN-GA2CARGIG, HRN-GA2EXTPWR, HRN-GA2NATRL, and
HRN-GA23WIRE, will be Taiwan.
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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division