The country of origin of a USB cable

N349947
June 18, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Wan Ru Laio Ching Tai Electric Wire & Cable Co., Ltd. No.5, Huacheng Rd., Xinzhuang Dist. New Taipei City 24252 Taiwan RE: The country of origin of a USB cable Dear Ms. Laio: In your letter dated June 8, 2025, you requested a country of origin ruling. The merchandise under consideration is identified as the USB A to C cable. The subject cable consists of a length of insulated conductor with a USB-A style connector at one end and a USB-C style connector at the other end. You state that the cable is a passive device used to transmit high-speed data signals between number of devices, such as computers and smartphones. You state that the manufacturing process begins in Taiwan with a copper wire conductor being extruded, twisted, braided, jacketed and insulated prior to being cut to the desired length. The unfinished cables will be shipped to China for the final manufacturing process. In China, the ends of the cable are prepared and the USB-A and USB-C connectors of Chinese origin are assembled onto each end of the cable. Then the finished cable is packaged for shipment 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). Regarding the origin of the subject cable, it is our opinion that the Taiwanese conductor wire imparts the character of the finished article as it is the essential electrical component of the cable. The addition of the connectors through the simple assembly process performed in China does not substantially transform the conductor cable into a new and different article of commerce. Based upon the facts presented, it is the opinion of this office that the origin of the USB A to C cable is Taiwan.

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,
(for) Steven A. Mack Director National Commodity Specialist Division