The country of origin of a wire harness

N353747 October 2, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Younger Wang BizLink Technology, Inc. 47211 Bayside Parkway Fremont, CA 94538 RE: The country of origin of a wire harness Dear Mr. Wang: In your letter dated September 15, 2025, you requested a country of origin ruling. The merchandise under consideration is identified by part number 2417608 and described as a wire harness used in snowmobiles. The subject harness is comprised of a bundle of insulated wire conductors, covered with tape and plastic and terminated at the various ends with connectors, terminals, fuses, and relays. The harness is placed within the snowmobile and is used to transfer electrical signals to various systems including lighting, sensors, and control modules. In your request, you state that you would like a ruling covering two manufacturing scenarios. In scenario one, you state that the manufacturing process occurs in China. This process begins with insulated wire, the vast majority of which originates from China, being laid out in the appropriate configuration, wrapped in plastic and taped together. The connectors, terminals, and other electrical components, which originate from China and Japan, are then attached to the ends before the finished harness is tested and packaged for shipment to the United States. In scenario two, the manufacturing process is the same as described above and occurs in China. However, in this scenario, 75 percent of the insulated wire is sourced from Taiwan, 20 percent from the U.S., and 5 percent from China. The terminals, connectors, and other electrical components are from China and Japan. 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 harness, it is the opinion of this office that the insulated wire imparts the character of the finished article. Further, the bundling and addition of connectors and terminals have routinely been found to be a simple process and would not substantially transform the wire into a new and different article of commerce. As the wire is not completely sourced from one country, it is our view that the country location where the bulk of the wire is sourced is where the critical electrical functionality is added. The country of origin for the wire harness, part number 2417608, will be China for scenario one and Taiwan for scenario two. 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