The country of origin of a flexible busbar

N353156
September 11, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a flexible busbar Dear Ms. Murrin: In your letter dated September 2, 2025, you requested a country of origin ruling on behalf of your client, ONOFF Electric Company, Inc. The merchandise under consideration, identified by model number GL0000047-0000, is described as an insulated flexible busbar, used in electrical distribution systems to conduct high current between components. The subject busbar is composed of thin layers of tinned electrolytic copper and is insulated with a halogen-free, flame-retardant, low-smoke material. As a finished product, the busbar is rated for 800A and features an insulation thickness of 1.8 mm. In your request, you state that the manufacturing process starts with the raw material for the busbar, referred to as the “soft busbar” being manufactured in France. The “soft busbar” is composed of thin layers of tinned electrolytic copper with high-resistance, halogen free, low smoke and flame-retardant insulation. The busbar is then exported from a distribution center in the Netherlands to China, where a series of finishing operations are performed to produce the final flexible busbar assembly. In China, the materials are cut to the specified length, skinned (removing of the insulation at both ends), filed and polished, punched, smoothed, bent and labeled, creating the finished flexible busbar assembly. 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). Based on the information provided, it is our opinion that the tinned copper layers, which are the conducting medium, impart the essential function component of the finished goods. The processing in China does not

substantially transform the busbar into a new and different article of commerce. Based upon the provided information, the origin of the flexible busbar, model number GL0000047-0000, is France. 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) Denise Faingar Acting Director National Commodity Specialist Division