The country of origin of RJ45 Patch Cords

N363607
August 4, 2026
OT:RR:NC:N2:220
CATEGORY: Origin Selina Lin Johnson Components and Equipments Co., Ltd. 14 Huacheng Rd., Xinzhuang District New Taipei City Taiwan RE: The country of origin of RJ45 Patch Cords Dear Ms. Lin: In your letter dated July 23, 2026, you requested a country of origin ruling on RJ45 Patch Cords. There are two RJ45 Patch Cords at issue in this request, individually identified by model names 0.75M RJ45 Patch Cord Cinnamon and 1.0M RJ45 Patch Cord Cinnamon. Both patch cords are identical except for the variation in length. Both patch cords consist of insulated electrical conductors with RJ45 style connectors attached to each end. In use, the subject patch cords are used to connect network devices and computers. In your request, you state that the manufacturing process begins in Taiwan, where a copper wire conductor is extruded, twisted, braided, jacketed, and insulated prior to being cut to the desired length. The unfinished cables will then be shipped to China for the final manufacturing process. In China, RJ45 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 country of origin of the subject patch cords, it is our opinion that the Taiwanese originating conductor wire imparts the character of the finished article as it is the essential component of the patch cords. The addition of Chinese origin connectors does not substantially transform the patch cords into new and

different articles of commerce with a name, character, and use distinct from the individual components. Based upon the facts presented, it is the opinion of this office that the origin of both the 0.75M RJ45 Patch Cord Cinnamon and 1.0M RJ45 Patch Cord Cinnamon 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 Gary Chaffee at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division