The country of origin of wiring harnesses

N358772 February 27, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Eleen Wee Nexus Advanced Manufacture SDN BHD 1209, JLN Perindustrian Bukit Minyak 18 Penang 14100 Malaysia RE: The country of origin of wiring harnesses Dear Ms. Wee: In your letter dated February 11, 2026, you requested a country of origin ruling. The merchandise under consideration is identified by part number 137636400 and described as a wiring harness for transmission control in ventilation systems. The subject harness is said to consist of a male D-Sub connector on one end, a length of Cat5e or 6 24/7 AWG stranded copper shielded cable with a TPE jacket sheathing, and a Mini-Fit Jr. connector on the other end. You state the harness carries control signals between sensors, controllers, and ventilation components, allowing the system to automatically control devices like fans and dampers to maintain proper airflow and environmental conditions. In your request, you state that the manufacturing process occurs in Malaysia. US sourced cable is cut to length and the ends are prepared for the addition of the US origin Mini-Fit Jr. connectors and the China origin male D-Sub connectors. The finished harness is labeled, tested for functionality, inspected, 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 wiring harness, it is the opinion of this office that the Cat5e or 6 cable manufactured in the United States imparts the character of the finished harness assembly as it is the functional component of the harness. Further, the assembly process performed in Malaysia, including the addition of the connectors, does not substantially transform the cable into new and different articles of commerce as their end use is predetermined and they perform the primary function of transmitting the data signals. Based upon the facts presented, the origin of the wiring harness, part number 137636400, 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 Gary Chaffee at gary.chaffee@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division