The country of origin of an LVDS cable

N347166
April 21, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Deborah Stern Sandler, Travis & Rosenberg, P.A. 5835 Waterford District Drive, Suite 200 Miami, FL 33126 RE: The country of origin of an LVDS cable Dear Ms. Stern: In your letter dated March 27, 2025, you requested a country of origin ruling on behalf of your client, Belden Inc. The merchandise under consideration, identified by model number SK-BV-3726, is described as a Low Voltage Differential Signaling (LVDS) cable. The subject cable consists of two copper core conductors and a single drain wire twisted together and wrapped in braiding, jacketing, and insulation. The cable is imported on reels and not terminated with connectors on either end. The subject cable is used as a high-speed data cable primarily as an audio and video interface in-vehicle infotainment systems. In your request, you state that the manufacturing process begins in Thailand with the creation of the copper conducting cores. Each core is manufactured by winding multiple individual copper wires, of Thai origin, together. These cores are then sent to China where they are wrapped with adhesive and then twisted together with a single drain wire before it is wrapped with a mylar layer and plastic tape. This semi-finished cable is then shipped to India where it is wrapped with aluminum and tinned-copper braiding to create a shield. The cable is then jacketed with insulation before the finished cable is tested and prepared for shipment to the United States. When determining the country of origin for purposes of applying current trade remedies under Section 301, 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 cable, it is the opinion of this office that the two copper cores, which are stranded and wound in Thailand, impart the character of the finished cable as they are the primary electrical

conducting component. The various steps performed in both China and India do not substantially transform the cores into a new and different article of commerce. Accordingly, the country of origin of the LVDS cable, model number SK-BV-3726, will be Thailand. 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 [email protected].
Sincerely,
Steven A. Mack Director National Commodity Specialist Division