The country of origin of a vehicle wire harness

N356155 November 26, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Sewon Lee Tiamo Customs Attorney 3-207, 495 Parang-ro, Seo-gu Incheon 22770 South Korea RE: The country of origin of a vehicle wire harness Dear Sewon Lee: In your letter dated November 17, 2025, you requested a country of origin ruling on behalf of your client, MFlex. The merchandise under consideration, identified by part number SZ000, is described as a wire harness specifically designed for motor vehicles. The subject harness is comprised of a group of insulated conductor wires bundled together and covered with plastic and terminated at the various ends with an assortment of connectors. The subject harness is used within the steering column of a vehicle in order to transmit various electrical signals throughout the vehicle. In your request, you state that the manufacturing process for the harness occurs in Vietnam using components sourced exclusively from Korea. The process begins with insulated wire of Korean origin being cut to length and the ends peeled in preparation for the assembly of the connectors. Each connector is then assembled in the appropriate configuration before the wires are bundled, covered with PVC tubing, and taped together. The finished harness is then tested for function and packaged for shipment to the United States. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) 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 wire harness, it is the opinion of this office that the Korean originating insulated wire imparts the character of the finished article. Further, the bundling and addition of various connectors has routinely been found to be a simple process and would not substantially transform the wire into a new and different article of commerce. In our view, the entirety of the process performed in Vietnam is simple in nature and does not render the Korean components transformed. Based upon the facts presented, it is the opinion of this office that the origin of the wire harness assembly, part number SZ000, will be 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division