RE: The country of origin of wire 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 N364542 September 3, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Ms. Cortney Morgan Husch Blackwell LLP 1801 Pennsylvania Avenue, NW, Suite 1000 Washington, DC 20006 RE: The country of origin of wire harnesses Dear Ms. Morgan: In your letter dated August 24, 2026, you requested a country of origin ruling on behalf of your client, Renaissance Network Reinvent. There are two wire harnesses at issue in this request, identified by part numbers 22147980-1 (Harness 1) and 22147981-1 (Harness 2). Both are electrical wire harnesses composed of individually insulated wire conductors bundled together and terminated at each end with specific electrical connectors or terminals, depending on the harness. Both harnesses are used to electrically connect a power output system to a test system. Specifically, Harness 1 connects the 120-240V AC input filter to the AC/DC converter, while Harness 2 routes the converted 48V DC power from the AC/DC converter to the test system’s backplane. The manufacturing process is described as follows: Insulated wire conductors of U.S. origin are imported into Canada, while additional components, including ring terminals, electrical contacts, connectors, heat shrink tubing, and protective sleeving are sourced from either the U.S. or another country and imported into Canada. In Canada, the wire is cut to length, the ends are stripped, and contacts are crimped onto the ends. The wires are then bundled together and wrapped in heat shrink and a protective braided sleeve. Connectors are added to each end according to customer specifications. Each harness is labeled, inspected, and mechanically and electrically tested prior to packaging for export to the U.S. When determining the country of origin for purposes of applying current trade remedies under Sections 301 and 232 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 wire harnesses, it is the opinion of this office that the U.S. origin insulated electrical wire imparts the character of the finished article as it provides the functional component of the harness. The additional work done in Canada, including stripping, crimping, bundling, and adding connectors does not substantially transform the U.S. cables into new and different articles of commerce with a name, character, and use distinct from the individual components. Based on the facts presented, it is the opinion of this office that for trade remedy purposes, the origin of the two wire harnesses, part numbers 22147980-1 and 22147981-1, will be the United States. 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