The country of origin of an audio adapter cable

N345387 February 3, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Joey Li Koda Electronics (HK) Co., Ltd 2/F Mandarin Commercial Building, 38 Morrison Hill Road, Wan ChaiHong KongChina RE:  The country of origin of an audio adapter cable Dear Mr. Li: In your letter dated January 24, 2025, you requested a country of origin ruling. The merchandise under consideration, identified by model number RX004, is further described as a Type C to 3.5mm audio adapter cable. The subject device is comprised of a length of insulated cable affixed with a USB-C connector at one end and a 3.5mm audio plug on the other. The purpose of the cable is to connect audio devices such as headphones or speakers to smartphones, tablets, and laptops that do not have a traditional audio connection. In your request, you state that the manufacturing process occurs entirely in Vietnam. Vietnamese originating insulated audio cable is cut to length and the ends are prepared for the addition of the connectors. A Chinese origin USB-C connector is soldered on one end before it is encased in plastic shielding, which is of Vietnamese origin. The audio connector, also originating from China, is then attached to the other end before further Vietnamese shielding is added. The finished cable is then inspected and packaged for sale 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 adapter cable, it is the opinion of this office that the Vietnamese insulated cable conductor imparts the character of the finished device. Further, the addition of the Chinese components does not substantially transform the cable into a new and different article of commerce. Based upon the facts presented, the origin of the Type C to 3.5mm audio adapter cable, model number RX004, is Vietnam.   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