The country of origin of extension cords

N342733 October 3, 2024 OT:RR:NC:N2:212 CATEGORY: Origin Eric Ge Talway Vietnam Company Limited T-2-1-1 and T-2-1-2, Que Vo Industrial Zone (Extension Area), Nam Son Ward, Bac Ninh CityBac Ninh Province 16000Vietnam RE:  The country of origin of extension cords Dear Mr. Ge: In your letter dated September 20, 2024, you requested a country of origin ruling. The merchandise under consideration is described as extension cords, which are identified by the part numbers listed below. We note that “xx” within the part numbers will be replaced by a number indicating the length in feet of the cord at importation into the United States.             909PR051510xxW             909PR051512xxW             909PR051514xxW             909PR051516xxW             909PR051518xxW The extension cords are manufactured in various lengths, color, and thickness and are intended for household use in either an indoor or outdoor capacity. The subject extension cords are comprised of a copper wire conductor that is covered with PVC insulation and fitted with a plug at one end and a receptacle at the other. We note that the cables are rated at 125 Volts. In your request, you state that the manufacturing process occurs in Vietnam and begins with Vietnamese single copper wire being stranded to the specific thickness. This conductor is then encapsulated with PVC insulation via the extrusion process before it is cooled and cut to length. Then Chinese origin power plugs and sockets are attached to each end of the cable. Once the cables are fully assembled, they are packaged for shipment to the United States. The "country of origin" is defined in 19 CFR 134.1(b) 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 origin of the subject extension cords, it is our opinion that the copper conductor, which originates from Vietnam, imparts the character of the finished article. Further, the addition of the Chinese power plugs and sockets do not substantially transform the insulated conductor into a new and different article of commerce with a name, character, and use distinct from the individual components. Based upon the facts presented, the origin of the various extension cords, represented by the below part numbers, will be Vietnam.             909PR051510xxW             909PR051512xxW             909PR051514xxW             909PR051516xxW             909PR051518xxW 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 luke.lepage@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division