The country of origin of an audio cable

N331939 April 19, 2023 OT:RR:NC:N2: 212 CATEGORY: Origin Jane Lee D and S Industries (Philippines) Corporation Unit 1-5 of Orient Goldcrest Suntrust Ecotown Building 2CavitePhilippines RE: The country of origin of an audio cable Dear Ms. Lee: In your letter dated April 3, 2023, you requested a country of origin ruling. The merchandise under consideration, identified by model number D05, is described as a 6-foot 3.5mm audio cable. The cable consists of a 6-foot length of insulated cable affixed with 3.5mm audio jacks on both ends of the cable.  The subject cable is used to connect a variety of audio devices such as headphones, stereo systems, laptops, and portable audio players. You state that the manufacturing process is fully completed in the Philippines. This process begins with bulk wire conductor being extruded, twisted, braided, jacketed, and insulated prior to being cut to the desired length. The ends are then prepared for the addition of Chinese connectors. The connectors are soldered and assembled onto each end before the cables are tested and packaged for shipment to the United States. The “country of origin” is defined in 19 CFR 134.1(b), in pertinent part, 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 this part.”  For tariff purposes, the courts have held that a substantial transformation occurs when an article emerges from a process with a new name, character or use different from that possessed by the article prior to processing. United States v. Gibson-Thomsen Co., Inc., 27 CCPA 267, C.A.D. 98 (1940); National Hand Tool Corp. v. United States, 16 CIT 308 (1992), aff’d, 989 F. 2d 1201 (Fed. Cir. 1993); Anheuser Busch Brewing Association v. The United States, 207 U.S. 556 (1908) and Uniroyal Inc. v. United States, 542 F. Supp. 1026 (1982). Regarding the country of origin of the subject cables, it is our opinion that the Philippines originating conductor wire imparts the character of the finished article as it is the essential component of the cable. The addition of the Chinese origin connectors does not substantially transform the cable into a new and different article of commerce with a name, character, and use distinct from the individual components. Based upon the facts presented, it is the opinion of this office that the origin of the 3.5mm audio cable, model number D05, is the Philippines. 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 luke.lepage@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division