The country of origin of an Ethernet Cable

N343287 October 24, 2024 OT:RR:NC:N2:212 CATEGORY: Origin Wan Ru Liao Ching Tai Electric Wire & Cable Co., Ltd. No.5, Huacheng Rd., Xinzhuang Dist.New Taipei City 24252Taiwan RE:  The country of origin of an Ethernet Cable Dear Ms. Liao: In your letter dated October 14, 2024, you requested a country of origin ruling. The merchandise under consideration is referred to as the RJ45 Patch Cord, which is further described as an ethernet cable. The cable consists of insulated cables in various lengths with RJ45 network connectors on each end. The subject cable is used to connect network devices and computers. You state that the manufacturing process begins in Taiwan with a copper wire conductor being extruded, twisted, braided, jacketed and insulated prior to being cut to the desired length. The unfinished cables will be shipped to China for the final manufacturing process. In China, RJ45 connectors of Chinese origin are assembled onto each end of the cable. Then the finished cable is 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 country of origin of the subject cable, it is our opinion that the Taiwanese originating conductor wire imparts the character of the finished article as it is the essential component of the cable. The addition of 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 RJ45 Patch Cable is 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division