The country of origin of clock spring assemblies for vehicles

N342924 October 17, 2024 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Country of Origin Jose Castro AlpsAlpine North America, Inc. 7100 International ParkwayMcAllen, TX  78503 RE:  The country of origin of clock spring assemblies for vehicles Dear Mr. Castro: In your letter dated September 27, 2024, you requested a country of origin ruling. The merchandise under consideration is referred to as a Clock Spring Assembly. There are four versions of the item, which are represented by part numbers ZWAC62A039A, ZWAC62A040A, ZWAC72A035A and ZWAC72A036A. The subject device consists of a wire harness attached to a cylindrical plastic housing within which is a flexible printed circuit ribbon cable with connectors at each end. The assembly is installed within the steering column of a vehicle and allows for the electrical systems and controls on the steering wheel to be connected to the vehicle’s electrical system while still allowing for the wheel to turn. These connections include the ignition, steering wheel controls, airbag, among others. Based upon the information provided, the only difference between the four models is the number of connection points and individual wires that make up the harness. The manufacturing process is the same for all four items with only minor differences based on how many wires and connectors are added within each assembly.  The steps are described as follows. In South Korea, the insulated conductor is created by stranding and winding individual wire and then covering with insulating material via an extrusion process. This cable is then sent to China where is it cut to length and connectors are added. In some instances, multiple cables are taped together to create more advanced harnesses. The flexible printed circuit ribbon cable is manufactured, via surface mount technology (SMT) in Japan and then sent to China. In China, the necessary connectors are soldered to the ends of the cable. The finished ribbon cable is then installed within the plastic housing along with various plastic parts including the roller assembly that allows the product to move freely. The finished wire harness is then electrically connected to the housing and ribbon cable to create the finished assembly. 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 clock spring assemblies, it is the opinion of this office that the function and character of the article is imparted by the completed wire harness. The device is primarily used for conducting and connecting electrical components within the vehicle, which may be enhanced by the presence of the ribbon cable and housing but is not significantly altered in a way to change the character of the harness. Further, the assembly process performed in China is not significantly complex to render the individual insulated conductors into a new and different article of commerce. Based upon the facts presented, the country of origin of the Clock Spring Assemblies, part numbers ZWAC62A039A, ZWAC62A040A, ZWAC72A035A and ZWAC72A036A, will be South Korea. 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