The country of origin of low voltage cables

N353664 September 30, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Byeongjun Kim Korea Customs Service (Busan Regional Customs) 26, Jungang-daero, Jung-Gu Busan 48942 South Korea RE: The country of origin of low voltage cables Dear Byeongjun Kim: In your letter dated September 12, 2025, you requested a country of origin ruling. There are three items at issue with this request, which are described as low voltage power cables. The first cable is identified as the XHHW, which is comprised of an aluminum conductor coated with cross-linked polyethylene (XPLE) insulation. We note that the cable is rated at 600 volts and is imported without any electrical connectors. The subject cable is meant to supply power in industrial and commercial applications, such as substations, power plants, and data centers. In your request, you state that the manufacturing process for this cable begins with the aluminum wire conductor being produced in China through drawing, annealing, and stranding procedures. The finished conductor is then sent to Korea where it is insulated with XPLE via an extrusion process. The finished cable is then tested and packaged for shipment to the United States. The second cable is identified as the Service Entry Round (SER) and is comprised of two to four XHHW cable cores wrapped in fiber tape and covered with PVC insulation. This cable is also rated at 600 volts and is not terminated with connectors. The cable is used to supply power withing residential and commercial buildings. The manufacturing process begins in China where the aluminum wire conductor is formed through the drawing, annealing, and stranding procedures, creating the XHHW conductor core. These cores are then sent to Korea where they are extruded with insulation material and bundled in the appropriate two or four-core configuration. The cores are then wrapped with fiber tape and a final layer of PVC insulation is extruded to complete the cable. This completed cable is then tested and packaged for shipment to the Untied States. The third cable is identified as the Metal-Clad (MC) and is comprised of two or more insulated XHHW cores which are wrapped in an aluminum sheath. The subject cables are rated at 600 volts and are not terminated with connectors. The cable is used as electrical wiring in commercial buildings and industrial plants. The manufacturing process begins in China where the wire conductor is formed through drawing, annealing, and stranding procedures, creating the XHHW conductor core. The core is then sent to Korea where it is insulated via the extrusion process and then bundled into the appropriate configuration. The cores are then wrapped with an aluminum tape shield before it is inspected and packaged for shipment to the Untied 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 cables, it is the opinion of this office that the conducting cores for all three versions impart the character of the finished articles as they produce the necessary electrical transmission function. Further, the insulation and other minimal procedures performed in Korea are simple in nature and would not substantially transform the aluminum conductors. Based upon the facts presented, the country of origin of the XHHW, SER, and MC low voltage cables will be China. 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