The country of origin of wire harnesses

N357149 January 8, 2026 OT:RR:NC:N2:212 CATEGORY: Origin Cortney Morgan Husch Blackwell LLP 1801 Pennsylvania Avenue, NW, Suite 1000 Washington, DC 20006 RE: The country of origin of wire harnesses Dear Ms. Morgan: In your letter dated December 17, 2025, you requested a country of origin ruling on behalf of your client WRWP, LLC. The merchandise under consideration, identified by part numbers 725-14625 and 725-18878, are described as wire harnesses specifically designed for a zero-turn riding lawnmower. The two harnesses are described as identical except for the final positioning of certain electrical components. The subject harnesses are comprised of a group of insulated conductor wires bundled together and covered with plastic tubing and terminated at the various ends with an assortment of connectors. The subject harness is used to electrically connect the battery, engine, hour meter, electric power take-off system (PTO), and the various switches in the lawn mower. The wire harnesses incorporate multiple relays and other electrical components for protection from short circuits and allow current to flow and activate the electric PTO to engage the mowing blades. In your request, you state that the manufacturing process for both harnesses begins with the sourcing of insulated wires which are manufactured in the United States. These U.S. originating wires are exported to China, where they are cut to varying lengths and the wire ends are stripped to prepare for the addition of the connectors and terminals. Wire junctions are spliced and heat shrinkable sleeving is applied to the spliced junctions, terminals, and/or wire bundles. Tape, harness covering wire ties, and/or clips are applied and harness covering tubing is slipped onto the wire harnesses. Relays and other additional electrical components are attached to the harnesses, then a visual inspection takes place to verify proper dimensions and presence of required components. Labels are applied and the finished wire harnesses are packed into cartons for shipping 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 wire harnesses, it is the opinion of this office that cable conductor, which originates in the U.S., imparts the character of the finished article as they are the functional components of the harnesses. Additionally, the work done in China, including cutting the wire, adding connectors and terminals, and adding components to the harnesses, does not substantially transform the cables into new and different articles of commerce with a name, character, and use distinct from the individual components. Based on the facts presented, it is the opinion of this office that the origin of the wire harnesses, part numbers 725-14625 and 725-18878, will be the United States. Whether an article may be marked with the phrase "Made in the USA" or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of proposed markings indicating that an article is made in the USA. 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