The country of origin of electrical wire harness assemblies

N357653 January 22, 2026 OT:RR:NC:N2:212 CATEGORY: Origin Eleen Wee Nexus Advanced Manufacture Sdn. Bhd. 1209, Jln Perindustrian Bukit Minyak 18, Kawasan Penang 14100 Malaysia RE: The country of origin of electrical wire harness assemblies Dear Ms. Wee: In your letter dated January 9, 2026, you requested a country of origin ruling on three models of electrical wire harness assemblies. There are three items at issue with this request, which are described as electrical wire harness assemblies. The first assembly, identified by part number ASY30734, is a wiring harness comprised of a bundle of individually insulated wire conductors terminated at each end with specific connectors. This assembly is used to provide electrical power and enable communication between the engine control unit (ECU) and the injection pump in a vehicle. It allows control of fuel quantity and injection timing according to engine speed and load. The second assembly is identified by part number 8874. This harness is comprised of a bundle of individually insulated wires terminated at each end with an assortment of connectors. This assembly is used to connect, transmit and protect electrical power and control signals between the ignition controller and the ignition system components in a vehicle. The third assembly is identified by part number ASY15433 and further described as a wiring harness used in an ignition booster module. The subject harness is comprised of a bundle of insulated wires terminated with connectors at each end. This assembly is used to transmit power, trigger signals and output current between the ignition system components, ensuring spark generation. In your request, you state that the manufacturing process for all three harnesses is substantially similar and described as follows. Insulated electrical conducting copper wire, coated with polyvinyl carbonate (PVC), is imported from China to Malaysia. Additionally, various terminals and connectors, which are manufactured in the multiple countries, are imported into Malaysia. In Malaysia, the copper conductor wires are cut to desired length and the ends are stripped in preparation for the addition of the terminals and connectors. The terminals and connectors are then assembled onto the ends and the conductors are bundled together into the appropriate configuration. The assembly harnesses are then tested, inspected, and packaged for export 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 harness assemblies, it is the opinion of this office that the Chinese originating cable imparts the character of the finished article as they are the functional component of the harness. Additionally, the Chinese wire assemblies are dedicated to use as the electrical conductors within the finished harness and are responsible for the primary connection and conduction functions. The additional work done in Malaysia, including stripping, crimping, and connecting terminals to the wire does not substantially transform the Chinese 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 three wire harness assemblies, identified by part numbers ASY30734, 8874, and ASY15433, 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