RE: The tariff classification, country of origin and marking of automotive wiring harnesses

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364497 September 4, 2026 CLA-2-85:OT:RR:NC:N2:220 CATEGORY: Origin Martin Robles K&K Interational Logistics 555 West Goldhill Road, Suite 32 Nogales 85648 RE: The tariff classification, country of origin and marking of automotive wiring harnesses Dear Mr. Robles: In your letter dated August 22, 2026, you requested a ruling on behalf of your client, EDS Manufacturing, Inc. This request covers five automotive wiring harness assemblies, identified by part numbers 2HH11-H994B-RH, 2HH11-K138B-RH, 2WH11-K015D, 2WH11-L8710, and 2WH12-L002B-LH. These assemblies consist of individually insulated electrical conductors bundled together, terminals, connector housings, seals, tubing, tape, grommets, splices, and related protective components. In use, these wiring harnesses provide electrical connectivity between various vehicle components. While each harness varies in function, layout, and complexity, the manufacturing process for all five is identical and follows these steps: Insulated cable conductors are manufactured in Mexico and shipped to El Salvador in bulk. Additional components, including terminals, connector housings, seals, tubing, tape, grommets, and splices, are sourced in El Salvador or imported from the United States, Mexico, China, Japan, Thailand, or Malaysia. In El Salvador, cables are cut to length, stripped, and crimped with terminals. Seals, grommets, heat-shrink tubing, and tape are applied according to individual harness specifications. The cables are then routed, bundled, and wrapped in protective tubing. After additional connectors and protective components are installed, the harnesses undergo electrical testing and inspection before being prepared for export to Mexico. In Mexico, the harnesses undergo final electrical testing and a dimensional inspection of critical characteristics. If necessary, the harnesses are reworked to meet specifications before being packaged for export to the United States. Classification You suggest the correction tariff classification for all five items is 8544.30.0000, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for all five automotive wiring harness assemblies will be 8544.30.0000, HTSUS, which provides for “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships.” The general rate of duty will be 5 percent ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. Country of Origin 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to
indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Regarding the origin of the automotive wiring harness assemblies, it is the opinion of this office that the insulated copper wire conductor manufactured in Mexico imparts the character of the finished automotive wiring harness assemblies as it is the functional component of the assemblies. Further, the assembly processes completed in El Salvador, using foreign components does not substantially transform the insulated conductor into a new and different article of commerce with a name, character, and use distinct from the individual components. Based upon the facts presented, the origin of the automotive wiring harness assemblies, part numbers 2HH11-H994B-RH, 2HH11-K138B-RH, 2WH11-K015D, 2WH11-L8710, and 2WH12-L002B-LH, will be Mexico. Marking Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. Since the subject merchandise is neither “wholly obtained or produced” nor “produced exclusively from domestic materials”, paragraphs (a)(1) and (a)(2) cannot be used to determine the country of origin of the cable, and paragraph (a)(3) must be applied to determine the origin of the finished article. As the subject cable, as noted above, is classified under 8544.30, HTSUS, the applicable tariff shift requirement in Part 102.20 states in pertinent part: A change to subheadings 8544.11 through 8544.70 from any other subheading, including another subheading within that group, except when resulting from simple assembly. Based upon the information provided, we find that all components of the subject assemblies satisfy the tariff shift rule and that the processes performed in El Salvador extend beyond the definition of simple assembly. As such, the country of origin for marking purposes of the automotive wiring harness assemblies, part numbers 2HH11-H994B-RH, 2HH11-K138B-RH, 2WH11-K015D, 2WH11-L8710, and 2WH12-L002B-LH will be El Salvador.
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