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