The country of origin of patch cord assemblies

N356327
December 3, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Crystal Yang ShenZhen ADTEK Technology Co., Ltd. 16/F, Building 1, Nanshan, iPark Chongwen, Shenzhen 518000 China RE: The country of origin of patch cord assemblies Dear Ms. Yang: In your letter dated November 21, 2025, you requested a country of origin ruling. The merchandise under consideration is described as four models of a fiber optic patch cord assembly, individually identified by part numbers F08M4QQBP, F02M4LL1R, F02S2LL1R, and F12M4QQBP. The subject assemblies are further described as fiber optic cables that consist of a fiber optic core, which consists of 2, 8, or 12 optical fibers, depending on the model. The fiber core is enclosed within a jacket and the cable assembly is terminated at each end with a fiber optic connector. The subject cables are used within various telecommunications industries to transfer optical data signals. In your request, you state that the manufacturing process for all four parts is substantially similar and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed with plastic and aramid yarn. The ends are then prepared for the addition of the connectors. The Chinese originating connectors are then assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S. 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 fiber optic cables, it is the opinion of this office that the fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce as their end use is predetermined and they perform the primary function of transmitting the data signals. Based upon the facts presented, the origin of the patch cord assemblies, part numbers F08M4QQBP, F02M4LL1R, F02S2LL1R, and F12M4QQBP, will be the United States. 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, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of proposed markings indicating that an article is made in the USA. 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 Luke LePage at [email protected].
Sincerely,
(for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division