The tariff classification, country of origin, and eligibility under the United States-Korea Free Trade Agreement (UKFTA) of electric vehicle charging cables

N359115 March 17, 2026 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Classification; Origin, Trade Programs TARIFF NO.: 8544.42.9090 Jiung Choi Yura Co. Ltd. 854 Sicheong-ro, Paltan-myeon Hwaseong-si, Gyeonggi-do 18529 South Korea RE: The tariff classification, country of origin, and eligibility under the United States-Korea Free Trade Agreement (UKFTA) of electric vehicle charging cables Dear Mr. Choi: In your letter dated February 24, 2026, you requested a ruling on the tariff classification, country of origin, and eligibility under the UKFTA for electric vehicle (EV) charging cables. The merchandise under consideration is a Liquid-Cooled High-Power EV Charging Cable Assembly, part number S8600-YR05X-A0-USG. The subject cable consists of three main parts, the EV Connector, liquid cooling hoses and stranded copper wire electrical conductors bundled together with a common outer jacket, and charging station termination connectors. Within the vehicle connector, temperature sensors prevent overheating and a push switch detects when the cable is connected and actively charging the vehicle. In your request, you state that the manufacturing process for the cable occurs in Korea. The bundled and insulated conductors are manufactured in Korea. The various connectors, terminals, clamps, switches, resistors, bolts, O-rings, seals, and molded plastic parts, which originate from the United States, China, Germany, and Korea, are assembled together to form the finished EV charging cable assembly. The finished assemblies are visually inspected and packaged for export. After importation, the station-side connector will be connected directly to an EV charging station. You state that the cable is rated at or below 1,000 Volts. Classification: The applicable subheading for the Liquid-Cooled High-Power EV Charging Cable Assembly, part number S8600-YR05X-A0-USG will be 8544.42.9090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Other electric conductors, for a voltage not exceeding 1,000 V: Fitted with connectors: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. Country of Origin: 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 country of origin of the subject cable, it is the opinion of this office that the Korea originating electrical conductors impart the character of the finished article and the addition of the connectors, cooling hoses, etc. do not substantially transform the cable into a new and different article of commerce. As such, the origin of the EV charging cable will be Korea. UKFTA: General Note 33, HTSUS, sets forth the criteria for determining whether a good is originating under the United States-Korea Free Trade Agreement (UKFTA). General Note 33(b), HTSUS, (19 USC 1202) states that: For the purposes of this note, subject to the provisions of subdivisions (c), (d), (n) and (o) thereof, a good imported into the customs territory of the United States is eligible for treatment as an originating good of a UKFTA country under the terms of this note if- (i) the good is wholly obtained or produced entirely in the territory of Korea or of the United States, or both; (ii) the good is produced entirely in the territory of Korea or of the United States or both, and – (A) each of the non-originating materials used in the production of the good undergoes an applicable change in tariff classification specified in subdivision (o) of this note; or (B) the good otherwise satisfies any applicable regional value-content or other requirements set forth in such subdivision (o); and satisfies all other applicable requirements of this note and of applicable regulations; or (iii) the good is produced entirely in the territory of Korea or the United States, or both, exclusively from materials described in subdivisions (i) or (ii), above. For goods classified under subheading 8544.42, HTSUS, General Note 33(o) states: 92. (A) A change to subheadings 8544.30 through 8544.49 from any other heading; or (B) A change to subheadings 8544.30 through 8544.49 from any other subheading, provided that there is also a regional value content of not less than: (1) 35 percent under the build-up method, or (2) 45 percent under the build-down method. Based upon the information provided, the components which originate outside of Korea, namely various connectors, terminals, clamps, switches, and resistors are all classified outside of heading 8544, HTSUS. As such, the EV charging cable makes the aforementioned tariff shift. Consequently, the subject cable is eligible for preferential treatment under the UKFTA. 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