RE: The country of origin of electrical appliance cords

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 N364973 September 24, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Mr. Mack Davis Well Harness Interconnect and Power PO Box 1586 Soddy Daisy, TN 37384 RE: The country of origin of electrical appliance cords Dear Mr. Davis: In your letter dated September 9, 2026, you requested a country of origin ruling on electrical appliance cords. The item at issue with this request is a finished appliance cord, part number H001-0019, which is an appliance cord used with major household appliances such as dishwashers. The appliance cord is stated to be five feet in length with a rating of 125 volts. It is constructed of 16 AWG SJT 3-conductor cable with a NEMA 5-15 plug head at one end and a strain relief at the other where the conductors are unterminated. In your request, you state that the manufacturing process occurs in both the United States and China. In the United States, 8.0 mm copper rod is drawn into copper wire which is then stranded and twisted to form 16 AWG. The finished conductor is then encased with a PVC insulating material. The cables are packaged onto large reels and exported to China. In China, the cables are cut to length and fitted with strain relief and plug head components. The finished appliance cords are tested, visually inspected and 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 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 battery cable, it is the opinion of this office that the copper wire manufactured in the United States imparts the character of the finished appliance cord as it is the functional component of the cord. Further, the additional manufacturing in China, including cutting to length, adding
plug head components, and testing 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 appliance cord, part number H001-0019, will be the United States. If a good is determined to be an article of U.S. origin, it is not subject to the country of origin marking requirements of 19 U.S.C. §1304. Whether an article may be marked with the phrase “Made in the USA” or similar words denoting U.S. origin, is an issue under the authority of the Federal Trade Commission (FTC). We suggest that you contact the FTC Division of Enforcement, 600 Pennsylvania Avenue, N.W., Washington, D.C. 20580 on the propriety of proposed markings indicating that an article is made in the U.S. 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