The country of origin and marking of an electrical cable assembly

N362463 July 1, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin and marking of an electrical cable assembly Dear Ms. Murrin: In your letter dated June 21, 2026, you requested a country of origin and marking ruling on behalf of your client, Aerospace Lighting Corporation for an electrical cable assembly. The merchandise at issue is an electrical cable assembly, identified by part number 91620-0004. This is a wiring harness comprised of a multi-wire primary cable (base cable) bundled with other individually insulated wire conductors and then terminated at each end with specific connectors. This electrical cable assembly is used to connect a printed circuit board inside a line replaceable unit (LRU). In aerospace and hardware engineering, an LRU is a self-contained component (like a radio or flight computer) that can be swapped out quickly for replacement or repair. The manufacturing process is described as follows. The U.S. origin base cable along with other insulated electrical wires are imported from Mexico and the United States to China. Various contacts, heat-shrink tubing, and connectors are imported into China where the copper conductor wires are cut to 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 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding the origin of the subject electrical cable assembly, it is the opinion of this office that the U.S. originating base cable imparts the character of the finished article as it provides the functional component of the harness. The U.S. base cable, serving as the primary conductor and, making up the majority of the wire in the harness by value, is dedicated to use as the primary electrical conductor within the finished harness and is responsible for the primary connection and conduction functions. The additional work done in China, including stripping, crimping, and adding connectors does not substantially transform the U.S. 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 part number 9 1620-0004 for marking and trade remedy purposes will be the United States. 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 P. Forkan Director National Commodity Specialist Division