The country of origin of fiber optic terminal boxes

N357615
January 20, 2026
OT:RR:NC:N2:212
CATEGORY: Origin Crystal Yang ShenZhen ADTEK Technology Co., Ltd. 16/F, Building 1, Nanshan iPark Chongwen Xili Nanshan, Shenzhen 518000 China RE: The country of origin of fiber optic terminal boxes Dear Ms. Yang: In your letter dated January 8, 2026, you requested a country of origin ruling. The merchandise under consideration is described as five models of fiber optic terminal boxes, represented by model numbers FPP-TN-NF-D1, FPP-TN-NF-D2, FPP-TN-NF-D3, FPP-TN-NF-86-V3, and HDPAS-M-FTTX. The subject terminal boxes consist of a fiber optic patch cord assembly, or jumper, attached to a splitter module within a plastic enclosure. The terminal boxes are used to provide fiber optic network connections within commercial and private installations. In your request, it is stated that the manufacturing process for all five models is the same. The process begins in the United States, where the optical fiber is created. This process includes the glass raw materials being treated, melted and drawn through various stages until the fiber reaches the appropriate diameter. The fiber is then coated with polymer before it is trimmed and tested for functionality. The finished fiber is then sent to China. In China, the fiber is cut to length, colored, and jacketed with Chinese PVC prior to connectors being added to the ends. This completed jumper assembly is then coiled onto a splice tray and the splitter modules are added onto the fiber, splitting the fiber into multiple outputs. The assembly is then enclosed within the plastic box with mounting hardware. The finished terminal box is tested and packaged for export to the United States. 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. Friedlander & 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. A substantial transformation occurs when, as a result of manufacturing process, a new and different article emerges, having a distinct name, character or use, which is different from that originally possessed by the article or material before being subjected to the manufacturing process. See United States v. Gibson-Thomsen Co., Inc., 27 C.C.P.A. 267 (C.A.D. 98) (1940). Regarding the origin of the subject terminal boxes, it is the opinion of this office that the jumper assembly, which is manufactured using U.S. origin optical fibers, imparts the character of the finished device. Further, the U.S. originating fiber is the essential transmission component of not just the jumper assembly, but the completed terminal box. The assembly process performed in China is not significantly complex in order to transform the U.S. components into new and different articles of commerce. Based on the facts presented, the country of origin of the fiber optic terminal boxes, model numbers FPP-TN-NF-D1, FPP-TN-NF-D2, FPP-TN-NF-D3, FPP-TN-NF-86-V3, and HDPAS-M-FTTX is 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division