The country of origin of vehicle wiring harnesses

N343697 November 12, 2024 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Country of Origin Jae Yeoung Cha SEIN Customs & Auditing Corp. 138, Seoun-ro, Seocho-guSeoul 06619South Korea RE:  The country of origin of vehicle wiring harnesses Dear Mr. Cha: In your letter dated November 1, 2024, you requested a country of origin ruling on behalf of your client, Hyundai Motor Company. There are two items at issue with this request, which are each described as wire harnesses for use specifically with motor vehicles. The first harness is identified by part number 39222-2S200 and is comprised of a group of insulated conductor wires bundled together and covered with plastic and terminated at the various ends with an assortment of connectors. You state that this harness is installed within the engine compartment and attached to the water temperature sensor in order to transfer electrical signals throughout the vehicle’s cooling system. The second harness is identified by part number 47891-4G000 and is also comprised of a group of insulated conductor wires bundled together and covered with plastic and terminated at the various ends with an assortment of connectors. You state that this item is installed within the suspension system of the vehicle in order to transfer the necessary electrical signals. In your request, you state that the manufacturing process for both parts is virtually identical and described herein. Insulated cable conductors as well as the various raw materials for the terminals and connectors are manufactured in South Korea and sent to China for further processing. In China, the cables are cut to the desired length and taped together in order to create the unterminated harness. The ends of the cables are then stripped and the connectors and terminals are assembled thereon. The finished harness is then shipped back to South Korea for final testing and packaging for shipment to the U.S. 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 wire harnesses, it is the opinion of this office that the South Korean originating cable imparts the character of the finished article as they are the functional components of the harnesses. Additionally, the Korean wire assemblies are dedicated to use as the electrical conductors within the finished harness and are responsible for the primary connection and conduction functions. The simple assembly performed to bundle the cables and add the connectors in China does not substantially transform the cables into new and different articles 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 wire harness assemblies, part numbers 39222-2S200 and 47891-4G000, 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