The country of origin of booster cables

N342864 October 8, 2024 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Country of Origin Letty Liu Wanjia Power Wire and Cable (Thailand) CO., Ltd 742/4 Moo 1 Tambon Nong Phai Kaeo, Amphoe Ban BuengChonburi 20200Thailand RE:  The country of origin of booster cables Dear Ms. Liu: In your letter dated September 26, 2024, you requested a country of origin ruling. There are five items at issue with this request, which are all described as automobile booster cables used to assist in charging the battery of the vehicle. The specific part numbers, as noted in your request, are 782-1653, 782-1654, 782-1655, 782-1656, and 782-1657. The cables are comprised of a length of insulated cable with varying thickness and length depending on the specific part number. Each has two electrical clamps at each end. In your request, you state that the manufacturing process is substantially similar for all of the cables and occurs in Thailand. Copper wire of Thai origin is twisted and braided before being insulated via an extrusion process. The various connectors and clamps, of Chinese origin, are then assembled and added to the ends of the cables. The finished cables are then retail 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 origin of the subject cables, it is our opinion that the Thai origin copper wire imparts the character of the finished articles. Further, the addition of the Chinese connectors does 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 booster cables, part numbers 782-1653, 782-1654, 782-1655, 782-1656, and 782-1657, will be Thailand. 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