The country of origin of a high speed cable

N348567 May 19, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Deborah Stern Sandler, Travis & Rosenberg, P.A. 5835 Waterford District Drive, Suite 200 Miami, FL 33126 RE: The country of origin of a high speed cable Dear Ms. Stern: In your letter dated May 2, 2025, you requested a country of origin ruling on behalf of your client, Belden, Inc. The merchandise under consideration, identified by model number SK-SFP-777, is described as an 8-pair high speed cable. The subject cable consists of 8 pairs of twinax wire conductors and a single drain wire wrapped in braiding, jacketing, and insulation. The cable is imported on reels and not terminated with connectors on either end. The subject cable is used as a high-speed data cable primarily used in data centers. In your request, you state that the manufacturing process begins with silver-plated copper conductor wire from either Germany or Vietnam being imported into China. In China, the conductor wire is extruded to add a layer of insulation, creating what you refer to as an insulated core. Next, two insulated cores are wrapped together with aluminum-mylar shielding and a drain wire for grounding to create the twinax conductor. The twinax conductors are then shipped to India, where 8 conductors are wrapped together with mylar and plastic tape and jacketed with a braided shield and a last layer of insulation. The finished cable is then put on a reel and prepared 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 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 cable, it is the opinion of this office that the silver-plated copper conductor wire imparts the character of the finished device as it is the primary electrical component. The various processes performed in China and India, including wrapping and insulating, do not substantially transform the conductor into a new and different article of commerce. Accordingly, the origin of the 8-pair high speed cable, model number SK-SFP-777, will be Germany or Vietnam, depending on where the copper conductor wire is manufactured. 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, (for) Steven A. Mack Director National Commodity Specialist Division