The country of origin of booster cables

N351558 July 30, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Eric Ge Talway Vietnam Company Limited T-2-1-1 and T-2-1-2, Que Vo Industrial Zone (Extension Area), Nam Son Ward Bac Ninh 16000 Vietnam RE: The country of origin of booster cables Dear Mr. Ge: In your letter dated July 22, 2025, you requested a country of origin ruling. The merchandise under consideration is described as vehicle booster cables, specifically identified by part numbers SAE0220, SAE0420, SAE0616, SAE0812, and SAE1012. The subject cables range from 10 to 20 feet in length and are comprised of a bundle of copper wire affixed at each end with a clamp connector. The cables further range in wire gauge from 2 AWG to 10 AWG. The subject cables are used to connect one vehicle’s battery to another in order to charge those with low power. In your request, you state that the manufacturing process for all five models is virtually identical and occurs primarily in Vietnam. A single strand of copper wire, which originates from China, is imported into Vietnam where it is tested and then wound together in the desired configuration. This bundling combines 98 to 465 strands of individual wire depending upon the wire gauge and electrical needs of the cable model. After the bundling, the cable is insulated through an extrusion process. The clamp connectors, which originate from China, are then assembled onto the end to complete the booster cables. 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 cables, it is the opinion of this office that the individual wire conductor is substantially transformed by the processes performed in Vietnam. The bundling and twisting of up to 465 strands of the wire significantly changes the electrical properties and capabilities of the individual strands. Combining this process with the insulation of the completed cable conductor further alters the electrical capabilities, rendering the individual strands as a new and different article of commerce. Based upon the facts presented, the country of origin of the booster cables, part numbers SAE0220, SAE0420, SAE0616, SAE0812, and SAE1012, will be 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, (for) James Forkan Acting Director National Commodity Specialist Division