The country of origin of a battery cable

N359118 March 4, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Chengye Wu PT. Safemate Electric Connection Indonesia Jalan Mandura Nomor 6 Kawasan Industri Kendal 51372 Indonesia RE: The country of origin of a battery cable Dear Mr. Wu: In your letter dated February 24, 2026, you requested a country of origin ruling. The merchandise under consideration is identified by part number BT-2001-4GA-12FT and described as a battery cable. The subject cable is said to consist of a length of insulated copper conductor cable 12 feet in length, with a battery terminal connector at one end and a grounding lug connector at the other end. In use, the cable is used to electrically connect the battery to a starter or a grounding location within a vehicle. In your request, you state that the manufacturing process occurs in Indonesia using the following steps. Copper wire of Indonesian origin is twisted and formed, then encased with a PVC insulating material. The cables are then cut to length and fitted with various connectors, of either Chinese or Indonesian origin, depending on the connector type. The finished cables are then packaged in retail blister packs 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 battery cable, it is the opinion of this office that the copper wire manufactured in Indonesia imparts the character of the finished battery cable as it is the functional component of the harness. Further, the addition of the Chinese connectors does not substantially transform the insulated conductor into a new and different article of commerce with a name, character, and use distinct from the individual components. Based upon the facts presented, the origin of the battery cable, part number BT-2001-4GA-12FT, will be Indonesia. 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