The country of origin of HDMI Cables

N344328 December 12, 2024 OT:RR:NC:N2:212 CATEGORY: Origin Wan Ru Laio Ching Tai Electric Wire & Cable Co., Ltd. No.5, Huacheng Rd., Xinzhuang Dist.New Taipei City 24252Taiwan RE:  The country of origin of HDMI Cables Dear Mr. Laio: In your letter dated December 2, 2024, you requested a country of origin ruling. The merchandise under consideration is referred to as a passive HDMI assembly, which is described as an HDMI cable. The device consists of a length of insulated cable affixed with passive HDMI Type-A connectors at each end. The finished cable is used to transmit audio and video signals between devices like TVs, monitors, and other media-enabled devices. In your request, you state that the manufacturing process begins in Taiwan with the creation of the insulated cable conductor. This process includes the drawing and twisting of the copper wire. This wire is then insulated and covered with aluminum before a braided copper shield is applied. A final outer sheath of insulation is then added before the bulk cable is sent to China for further processing. In China, the cable is cut to the desired length and the ends are prepared for the addition of the connectors. The connectors are then assembled on each end before the finished device is packaged for shipment to the U.S. When determining the country of origin for purposes of applying current trade remedies under Section 301, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Regarding the origin of the subject cables, it is our opinion that the Taiwanese origin conductor imparts the character of the device. Further, the addition of the connectors in China 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 HDMI Assembly, 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