The country of origin of hardline digital cable

N350106 June 24, 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 hardline digital cable Dear Ms. Stern: In your letter dated June 11, 2025, you requested a country of origin ruling on behalf of your client, PPC Broadband Inc. The merchandise under consideration, identified by model number PPC625EFRF, is described as hardline cable, also known as feeder or trunk cable. The subject cable is constructed of a copper-clad aluminum conducting core wrapped in insulation, an internal shield, and a protective jacket. We note that the cable is imported on reels and not terminated at either end with a connector. The subject cable will be used to transmit digital communication signals over long distance where high strength cables are needed, such as in outdoor installations. In your request, you describe the manufacturing process begins with the copper-clad aluminum conductor of either South Korean or U.S. origin being imported into China. In China, the internal insulation is extruded over the conductor, creating the insulated core. An aluminum shield is then formed around the core before plastic jacketing is added to complete the finished cable. The cable is then wound onto 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 and additional duties, 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 hardline cable, it is the opinion of this office that the copper-clad aluminum conducting core imparts the character of the finished article. The process of adding insulation, shielding, and jacketing does not substantially transform the conductor into a new and different article of commerce. Based upon the facts presented, the country of origin of the hardline cable, model number PPC625EFRF, will be South Korea or the United States, depending on the origin location of the conductor. Whether an article may be marked with the phrase "Made in the USA" or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of proposed markings indicating that an article is made in the USA. 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