The country of origin of an automotive wire harness

N356930 January 5, 2026 OT:RR:NC:N2:212 CATEGORY: Origin Jay Cho Aprio Advisory Group LLC 2002 Summit Blvd NE Suite 120 Atlanta, GA 30319 RE: The country of origin of an automotive wire harness Dear Mr. Cho: In your letter dated December 11, 2025, you requested a country of origin ruling on behalf of your client, Kyungshin America Corporation. The merchandise under consideration is described as an automotive wiring harness. The subject harness is comprised of various individually insulated wire conductors, bundled together and terminated at the ends with various terminals and connectors. The harness is specifically designed to be used in vehicles to connect electrical and electronic systems, including lighting, sensors, engine controls, and infotainment. In your request, you state that the assembly process occurs in the Philippines. This process begins with the importation of the various components, including the insulated wire conductors, which originate in Korea. These conductors are cut to the appropriate length and the terminals, which originate primarily from Korea as well, are assembled onto the ends. The conductors are then bundled together, and connectors are added where needed. The finished harness is then tested for functionality 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 harness, it is the opinion of this office that the insulated wire conductors impart the character of the device as they perform the essential electrical transmission functions. Further, the assembly processes performed in the Philippines do not substantially transform these Korean components. As such, based upon the facts presented, the country of origin of the automotive wire harness 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division