The country of origin of Octal Small Form Factor Pluggable transceiver modules

N361198May 18, 2026OT:RR:NC:N2:209
CATEGORY: OriginLisa MurrinExpeditors Tradewin LLC795 Jubilee DrivePeabody, MA 01960RE: The country of origin of Octal Small Form Factor Pluggable transceiver modulesDear Ms. Murrin:In your letter dated
May 4, 2026
, you requested a country of origin ruling on behalf of your client, AperionTechnologies, for ctal Small Form Factor Pluggable transceiver modules.OThe item concerned referred to as ctal Small Form Factor Pluggable transceiver modulesare O(OSFP) s,model numbers 800G OSFPDR8, 800G OSFP2xDR4, 800G OSFP2xFR4, 1.6T OSFP2xDR4, and 1.6Tver module will be mounted to each end of a length of fiber optic cable. TheOSFP2xFR4. These transceissubject merchandise is a hot-pluggable modul that plugs into network devices, such as switches in dataecenters. It is used to convert an electrical signal into an optical signal, and conversely an optical signal backinto an electrical signal. These transceivers are designed for use in 800 Gigabit Ethernet links on up to 500mof single mode fiber. They are used for networking in the data communications sector to receive, convert, andtransmit different signals.We agree that these OSFP transceiver modules are similar to the ones discussed in rulings , datedN358465February 27, 2026 and , dated Sepember 10, 2025N352670t.The main components of the OSFP transceiver are the printed circuit board assembly (PCBA), the opticalsubassembly (OSA), and the transceiver housing.Scenario 1OSA (China-Origin):The OSA includes both a TOSA (transmit optical subassembly) and a ROSA (receive optical subassembly).The TOSA and ROSA are referred to as “Tx” and “Rx.”The Tx (transmitter) part of the OSA is responsible for converting the electrical signals into optical signalsand transmitting these signals over the optical fiber strand in the FA (fiber array) connected to it. One laser
diode unit generates and focuses a light beam into a SiPho (Silicon Photonic) integrated circuit. The photonicintegrated circuit splits the light signal into four light beams and takes electrical signals from the main PCBAto modulate the four collected light beams. Then, four lights are launched into the optical fibers of the FA viathe isolator focus optics. The light beams then travel to the receptacle connector and out of the opticaltransceiver. The Tx part of the OSA is manufactured in China and attached to the Malaysia origin PCBA inChina.The Rx (receiver) part of the OSA is responsible for receiving the optical signals transmitted from the Tx partof the transceiver and converting them back to electrical signals so that the communication equipment canunderstand them. The Rx part of the OSA consists of an Rx block, four photodiodes, two single-layercapacitors, and a transimpedance amplifier. The Rx part of the OSA receives four light beams from opticalfibers and sends them to four photodiodes. It is the photodiodes that convert the light signals into electricalsignals which are then amplified by the transimpedance amplifier on the PCBA. The Rx part of OSA ismanufactured in China and attached to the Malaysia origin PCBA in China.Main Board PCBA (Malaysia-origin)The Main Board PCBA contains approximately 560 electrical elements sourced from various countries oforigin. The main electrical element on the PCBA is the digital signal processor (DSP) chip of U.S.-origin.This is the highest value item on the BOM and a critical component of the PCBA. The Main Board PCBA isthe foundation of the transceiver and imparts its essence. Without the Main Board PCBA, the Tx part of theOSA cannot generate optical signals and the Rx part of the OSA cannot convert optical signals into electricalsignals.The DSP provides for signal amplification, detection, regeneration, and reconditioning. The DSP works withthe OSA and provides electrical driving signals for the OSA (both the Tx and Rx). The DSP signals the laserdiode of the Tx side of the OSA to emit optical signals into the fiber array and out of the transceivers. TheDSP also processes optical signals from the fiber array into the transceiver on the Rx side of the OSA. Thesignal is not readable by the OSA until it is formatted by the DSP chips. On the receiving side, when theoptical transceiver receives a signal from the OSA and converts the optical signal to electrical signal, theelectrical signal is not readable by the optical transceiver until it undergoes further processing from the DSP.The Main Board PCBA also contains an erasable programmable read-only memory chip (EPROM) that willbe programmed in Malaysia to provide the required instructions to perform the transceiver function. TheEPROM information is saved in the flash memory of the MCU IC (Accelink PCBA Part Number 20719401on the BOM). More than three-fourths of the total components of the transceiver are on the Main BoardPCBA.Manufacturing of the Main Board PCBA in Malaysia:Production in Malaysia includes the creation of the PCBA via surface mount technology (SMT). The PCBAconsists of numerous components/elements from various countries of origin. The SMT process is amultistage process requiring different types of specialized machines. The SMT process for the PCBA is asfollows:1.Solder paste printing. 2.Solder paste inspection (SPI). 3.SMT by means of a pick-and-place machine is used to populate the board with approximately 560 dedicated PCBA components.4.Solder reflow to permanently adhere the components to the board. 5.Optical inspection (AOI). 6.Automated 3D x-ray inspection. 7.Another round of the SMT subprocess, repeating all previous steps.
8.Conformal coating in order to protect the PCBA and its components. The coating is then dried and baked.9.Manual visual inspection via microscope .Once the PCBA is assembled, it is sent to China where the OSA is attached.Manufacturing Steps in China: Attaching the OSA to the PCBA1.Receive PCBA from Malaysia. 2.Attach the SiPo, laser diode, and substrate onto PCBA. 3.Perform wire bonding. 4.Attach the isolator to the PCBA with epoxy curing. 5.Attach and align Lens 1 to the PCBA with epoxy curing. 6.Attach and align Lens 2 to the PCBA with epoxy curing. 7.Attach and align the Tx Fiber Array with epoxy curing. 8.Rx FA alignment and attach with epoxy curing. 9.Attach a cover to protect the OSA on PCBA. 10.Test and inspect the OSA-on-PCB A.The OSA-on-PCBA is then returned to Malaysia where it is assembled into the finished transceiver.Final Assembly in Malaysia:Once the OSA-on-PCBA arrives back in the Malaysia, thermal grease is added to the light source in order toensure heat dissipation and a component for heat release is attached to the light source. Next, an OSA coveris attached to the OSA via a UV curing and baking process. Next, the fiber router is attached, which routesfibers between the Tx part of the OSA subassembly, the Rx part of OSA subassembly, and the fiberconnectors. Lastly, thermal pads are attached to allow the entire optical transceiver to dissipate heat. Once theabove manufacturing in Malaysia is completed, the mechanical housing is attached to the parts, the softwareis loaded, and the transceiver undergoes electrical and optical performance tuning, testing, and qualityassurance.Scenario 2The manufacturing process for scenario 2 is similar to those in scenario 1 in relation to the work done in China. The main difference between the two scenarios is the manufacturing process in regard to the MainBoard PCBA.Main Board PCBA (U.S.-origin)The Main Board PCBA contains the digital signal processor (DSP) chip of U.S.-origin. This part is thehighest value part on the BOM and a critical component of the PCBA. The Main Board PCBA is thefoundation of the transceiver and imparts its essence. Without the Main Board PCBA, the Tx part of the OSAcannot generate optical signals and the Rx part of the OSA cannot convert optical signals into electricalsignals.The DSP provides for signal amplification, detection, regeneration, and reconditioning. The DSP works withthe OSA and provides electrical driving signals for the OSA (both the Tx and Rx). The 4 DSP signals thelaser diode of the Tx side of the OSA to emit optical signals into the fiber array and out of the transceivers.The DSP also processes optical signals from the fiber array into the transceiver on the Rx side of the OSA.The signal is not readable by the OSA until it is formatted by the DSP chips. On the receiving side, when theoptical transceiver receives a signal from the OSA and converts the optical signal to electrical signal, theelectrical signal is not readable by the optical transceiver until it undergoes further processing from the DSP.
The Main Board PCBA also contains an erasable programmable read-only memory chip (“EPROM”) thatwill be programmed in the U.S. to provide the required instructions to perform the transceiver function. TheEPROM information is saved in the flash memory of the MCU IC (Accelink PCBA Part Number 20719401on the BOM). In addition to the DSP chip and the EPROM, the PCBA consists of approximately 560electrical components from various countries of origin. More than three-fourths of the total components ofthe transceiver are on the Main Board PCBA.Manufacturing of the Main Board PCBA in United States:Production in the U.S. includes the creation of the PCBA via surface mount technology (“SMT”). The PCBAconsists of numerous components/elements from various countries of origin. The SMT process is amultistage process requiring different types of specialized machines. It takes 10.2 minutes to assembly thePCBA in a fully automated process using specialized equipment. The SMT process for the PCBA is asfollows:1. The printed circuit board will undergo solder paste printing.2. The board will undergo an initial solder paste inspection (“SPI”).3. The board’s solder side will be surface-mounted by means of a pick-and-place machine thatpopulates the solder side of the board with its dedicated PCBA components.4. The solder side will undergo solder reflow to permanently adhere the components to the board.5. The PCBA will undergo automated optical inspection (“AOI”).6. The PCBA will undergo an automated 3D x-ray inspection.7. The PCBA will undergo another round of the SMT subprocess, repeating all previous steps.8. The PCBA will then undergo conformal coating in order to protect the PCBA and its componentsfrom moisture, dust, or other forms of damage. The coating is then dried and baked.9. The PCBA will undergo a manual visual inspection via microscope.Once the PCBA is assembled, it is sent to China where the OSA is attachedWhen determining the country of origin for purposes of applying current trade remedies under Section301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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).Based upon the facts presented, it is the opinion of this office that the manufacturing processes that take placewithin Malaysia for scenario 1 and the United States for scenario 2 to create the main PCBA is bothsubstantial and complex. The character of this product is imparted by the main PCBA which would beconsidered the dominant component of this assembly. The assembly/manufacturing process that takes placein China does not change the end use of the main PCBA. The PCBA does not undergo a substantialtransformation as a result of the Chinese processing. Therefore, since a substantial transformation does notoccur as a result of the Chinese processing, the country of origin ctal Small Form Factor Pluggable of the Otransceiver module(OSFP) s, model numbers 800G OSFPDR8, 800G OSFP2xDR4, 800G OSFP2xFR4, 1.6Twill be alaysia for scenario 1 and the United States for scenario 2OSFP2xDR4, and 1.6T OSFP2xFR4 M forthe purpose of applying current trade remedies and additional duties.If a good is determined to be an article of U.S. origin, it is not subject to the country of origin markingrequirements 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 asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Steven Pollichino at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division