The country of origin of cable testers and cable trackers

N351914 August 25, 2025 OT:RR:NC:N1:105 CATEGORY: Origin Chuhao Lan Yingke Law Firm 39F, 501, Yincheng Middle Road, Pudong New District Shanghai 20012 China RE: The country of origin of cable testers and cable trackers Dear Ms. Lan: In your letter dated August 1, 2025, on behalf of your client, Shanghai SDAR Electronic Instruments, Co., Ltd., you requested a country of origin ruling on cable testers and cable trackers. Descriptive literature was provided for our review. The first items under consideration are described as cable testers (model numbers 33-856 and 62-200), which are electronic instruments that test and diagnose signal integrity in various types of cables. The 33-856 and 62-200 cable testers differ slightly in functionality. The 33-856 model provides comprehensive cable testing for voice, data and video applications. The device can not only detect cable continuity and verify wiring sequence, but also comprehensively evaluate overall cable condition and precisely identify specific faulty wires. The 62-200 model consists of a pair of detectors specifically designed for voice and data applications. While it can also test continuity and wiring sequence, it only displays results through LED indicators and lacks coaxial cable testing capability. The second items under consideration are described as cable trackers (model numbers 62-164, 62-140, and 62-160), which are electronic instruments that judge continuity of the cables, track the cables, and diagnose the broken point. The 62-164 tester is an auxiliary device that must be used in conjunction with either the 33-856 or 62-160 equipment, as it does not possess standalone testing capabilities. The 62-160 is equipped solely with a signal generator module, which generates a signal to be received by the 62-164 for the purpose of cable tracing. The 62-140 has both a generating and receiving mode, which can solely achieve cable tracking. The third items under consideration are described as cable-tester kits (model numbers 33-866 and 33-864), which are a combination of the articles in items one and two referenced above. The 33-886 kit includes the 33-856 cable tester and the 62-164 cable tracker, offering both cable testing and remote cable tracking functions. The 33-864 kit comprises the 62-164 and 62-160 cable trackers and are designed solely for remote cable tracking. The manufacturing and assembly process for both the cable testers and cable trackers occurs in Vietnam with a substantially similar process. Additionally, the manufacturing process for the kits is identical to that of their individual components. It starts with the creation of the printed circuit board assembly (PCBA) using surface mount technology (SMT) in Vietnam. The electronic components (resistors, capacitors, etc.) from various countries are mounted onto the printed circuit board (PCB). This involves a solder paste application, placement of components, reflow soldering, cleaning, and testing to ensure circuit functionality. The next process also occurs in Vietnam and includes the chip-on-board (COB) bonding. This is applicable to the 33-856 cable tester and involves PCB cleaning, glue dispensing, unpackaging the semiconductor die attached to the PCB, wire bonding, testing, and epoxy encapsulation. Finally, the remaining larger components are manually inserted and soldered onto the PCB. After assembly, the final inspections and testing are performed to ensure accuracy of the units. The final assembly and inspection process then shifts to China where the completed PCBA is installed into the Chinese-origin plastic housings along with other components manufactured in China. These include the LCD displays/LED indicators and probe tip. When determining the country of origin, 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 country of origin of the cable testers (model numbers 33-856 and 62-200), the cable trackers (model numbers 62-164, 62-140, and 62-160), and the cable-tester kits (model numbers 33-866 and 33-864), it is our opinion that the assembly process performed in Vietnam is considered complex and results in a substantial transformation of over a hundred different components. Most importantly, the creation of the PCBA in Vietnam using SMT generates a working measuring device. This PCBA creation and additional assembly in Vietnam creates a new and different article of commerce with a name, character, and use distinct from the individual Chinese and foreign components. Accordingly, the country of origin of the cable testers (model numbers 33-856 and 62-200), the cable trackers (model numbers 62-164, 62-140, and 62-160), and the cable-tester kits (model numbers 33-866 and 33-864) will be Vietnam, which is where the PCBA creation, programming and major assembly occurs. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division