The country of origin of automotive wiring harnesses

N361726June 3, 2026OT:RR:NC:N2:220
CATEGORY: OriginHanjin LeeDaemoon Customs Firm76 Yeonmujang-gil, Seongdong-guSeoul 04784South KoreaRE: The country of origin of automotive wiring harnessesDear Hanjin Lee:In your letter dated
May 22, 2026
, you requested a country of origin ruling on automotive wiring harnesses.There are five wire harnesses under consideration with this request, which are individually identified as PartNo. 91200-EV340 Front Wire Harness (Item 1); Part No. 91625-DS020 Rear Door LH Wire Harness (Item2); Part No. 91803-EV110 Roof Wire Harness (Item 3); Part No. 91662-DS510 HV Cable No. 1 WireHarness (Item 4); and Part No. 91855-DS010 BATT+ Wire Harness (Item 5).Item 1 is a front wiring harness comprised of a group of individually insulated conductor wires bundledtogether and covered with plastic tape and terminated at the various ends with an assortment of terminals andconnectors. The harness is installed within the engine compartment of a vehicle and connected to the junctionblock, wheel sensors, cooling hose sensors, battery sensors, headlamps, ECU, airbag, and pedal sensors inorder to supply power and transmit electrical signals between the vehicle's electrical components.Item 2 is a rear door wiring harness comprised of a group of individually insulated conductor wires bundledtogether and covered with plastic tape and terminated at the various ends with an assortment of terminals andconnectors. The harness is installed within the rear door of a vehicle and connected to the enginecompartment, dash panel interior, and various electrical components in order to supply power and transmitelectrical signals to the door-mounted electrical devices.Item 3 is a roof wiring harness comprised of a group of individually insulated conductor wires bundledtogether and covered with plastic tape and terminated at the various ends with an assortment of terminals andconnectors. The harness is installed within the roof panel of a vehicle and connected to the overhead consolelamps, vanity lamps, auto defog sensor, sunroof motor and switch, room mirror, and front camera in order tosupply power and transmit electrical signals to the roof-mounted electrical devices.
Item 4 is a high-voltage wiring harness comprised of a group of individually insulated conductor wiresbundled together and covered with plastic tape and terminated at the various ends with an assortment ofterminals and connectors. The harness is installed within the engine compartment of a vehicle and connectedto the high voltage components via the junction block in order to supply high voltage power and transmitelectrical signals between the high voltage electrical components of the vehicle system.Item 5 is a positive side battery wiring harness comprised of a group of individually insulated conductorwires bundled together and covered with plastic tape and terminated at the various ends with an assortment ofterminals and connectors. The harness is installed within the battery pack of a vehicle and connected to theengine compartment and various electrical components in order to transmit high-voltage power from thebattery through the junction block to the vehicle's electrical loads.While each harness varies in function, layout, and complexity, we note that the manufacturing process for allfive harnesses is virtually identical and described as follows. Insulated cable conductors are manufactured inSouth Korea and sent to Vietnam in bulk quantities. Other components including relays, connectors,grommets, terminals, etc. are sourced either in Vietnam or imported from other countries including SouthKorea, Japan, Germany, the United States, etc. In Vietnam, the cables are cut to the desired length, the endsare stripped, and terminals are crimped onto the ends. After an initial quality inspection of the wire cables,they are grouped according to the harness specifications and inserted into their terminating connectors tocreate a sub-assembly. Various sub-assemblies are gathered and routed according to harness specifications ona layout board where they are taped and mounting clips are added at various intervals. A final qualityassurance check in conducted and the finished harnesses are 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 RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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 wire harnesses, it is the opinion of this office that the South Koreanoriginating cable impart the character of the finished article as they are the functional components of thessharnesses. Additionally, the Korean wire assemblies are dedicated to use as the electrical conductorsSouth within the finished harness and are responsible for the primary connection and conduction functions. Theaddition of the connectors as well as the assembly performed to bundle the cables in V does route andietnamnot substantially transform the cables into new and different articles of commerce with a name, character, anduse distinct from the individual components. Based upon the facts presented, it is the opinion of this officethat the origin of the wire harness assemblies, Part No. 91200-EV340 Front Wire Harness (Item 1); Part No.91625-DS020 Rear Door LH Wire Harness (Item 2); Part No. 91803-EV110 Roof Wire Harness (Item 3);Part No. 91662-DS510 HV Cable No. 1 Wire Harness (Item 4); and Part No. 91855-DS010 BATT+ WireHarness (Item 5), will be South Korea.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Gary Chaffee at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division