OT:RR:NC:N2:212
Alexander Morton
Chogori Technologies Inc
2915 Ogletown Rd.
Newark, DE 19713
RE: The country of origin of an electrical cable assembly
Dear Mr. Morton:
In your letter dated January 6, 2026, you requested a country of origin ruling.
The merchandise under consideration is described as an electrical cable assembly and is identified by part
number HRN-RCCCAAPX. The subject assembly is comprised of a shielded and insulated cable conductor,
terminated with a molded Mini-Series 6-pin connector at each end. The assembly is used to connect the
refrigerator unit of a truck to the onboard telematics system.
In the request, you state that the manufacturing process begins in Taiwan where a copper conductor is created
by stranding and twisting the individual copper wire into the appropriate configuration. The conductors are
further extruded with PVC insulation, shielded and jacketed. The cable is then tested and sent to China. In
China, the ends of the cables are stripped, terminals are crimped and connectors are assembled to the ends.
Final inspection takes place and the electrical cable assembly is exported to the United States.
Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every
article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly,
indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to
indicate to the ultimate purchaser in the United States, the English name of the country of origin of the
article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to
know by an inspection of the marking on the imported goods the country of which the goods is the product.
The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by
knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
A substantial transformation occurs when, as a result of manufacturing process, a new and different article
emerges, having a distinct name, character or use, which is different from that originally possessed by the
article or material before being subjected to the manufacturing process. See United States v.
Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940).
Regarding the origin of the subject electrical 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 electrical cable assembly, identified by part number HRN-RCCCAAPX, 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)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division