The country of origin of fiber optic patch cord assemblies

N357758
January 29, 2026
OT:RR:NC:N2:212
CATEGORY: Origin Gena Haddock Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of fiber optic patch cord assemblies Dear Ms. Haddock: In your letter dated January 13, 2026, you requested a country of origin ruling on behalf of your client, SJ Photons Technology America, Inc. The merchandise under consideration is described as five models of fiber optic patch cord assemblies, identified by part numbers HJGRXRX3W, HJGRPRP3W, HJGQXQXTM, UJFRXQX3W, and UGGQXQXTL. The subject assemblies are further described as fiber optic cables made of glass fibers, reinforced with aramid yarn, and bundled in a plastic jacket with connectors. 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 five part numbers is identical and begins with the creation of the optical fiber in the United States. The 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. The fiber is then coated with dual-layer acrylate, tested, then exported to China. In China, the fiber core is cut to length prior to being colored and jacketed with plastic. The ends are fanned out and prepared for the addition of connectors. The connectors are assembled onto the ends, and the finished cable assembly is tested, packaged, and exported 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 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 HJGRXRX3W, HJGRPRP3W, HJGQXQXTM, UJFRXQX3W, and UGGQXQXTL, 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division