The country of origin of cable assemblies

N353657 September 24, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Byung ho Park SEIN Customs & Auditing Corp 138, Seoun-ro, Seocho-gu Seoul 06619 South Korea RE: The country of origin of cable assemblies Dear Mr. Park: In your letter dated September 11, 2025, you requested a country of origin ruling on behalf of your client, Molex, LLC. There are two items at issue with this request, which are each described as Feeder Cables and individually identified by part numbers 96220-P8500 and 96230-P8300. Both items are comprised of a length of insulated coaxial cable with various connectors at each end. The cables are meant to be used within vehicle telematics and infotainment systems in order to transmit radio frequency (RF) signals within the various components of the vehicle. In your request, you state that the assembly process for both cables is significantly similar and begins with the Korean coaxial cable being imported into Vietnam. In Vietnam, the cable is cut to length and the connectors, which originate from Korea, are assembled onto the ends. Various clips and pads are added before the finished cables are inspected and packaged for shipment to the United States. 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 feeder cables, it is the opinion of this office that the Korean coaxial cable imparts the character of the finished device. Further, the assembly process performed in Vietnam is simple in nature and does not result in a substantial transformation of the Korean components. Based upon the facts presented, the country of origin of the Feeder Cables, part numbers 96220-P8500 and 96230-P8300, will be South Korea. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division