OT:RR:NC:N2:220
Alexander Morton
Chogori Technologies Inc
2915 Ogletown Road
Newark, DE 19713
RE: The country of origin of an electrical cable assembly
Dear Mr. Morton:
In your letter dated March 26, 2026, you requested a country of origin ruling on an electrical cable assembly.
The merchandise at issue is an electrical cable assembly, identified by part number 1IC03525070701. The
subject cable is comprised of a multi-core primary cable and a single-core hook-up wire. These are shielded
and insulated with a 6-pin connector attached to one end. The cable assemblies are used to deliver electrical
and communication signals within a telematics device system.
The manufacturing process for the primary cable and the single-core hook-up wire is essentially 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. In China the completed primary cable and single-core hook-up wire are cut to length, stripped
and terminals are crimped onto the conductors. A 6-pin connector is assembled onto one end, and 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 (“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 cable assembly, it is the opinion of this office that the insulated copper
conducting core imparts the main character of the finished article. Further, the addition of the connectors in
China is not significantly complex; therefore, it does not substantially transform the conductor into a new and
different article of commerce. As such, the country of origin of the cable assembly, part number
1IC03525070701 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 Gary Chaffee at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division