The country of origin of fiber optic patch cord assemblies

N361573May 19, 2026OT:RR:NC:N2:220
CATEGORY: OriginCindy YangADTEK Industrial (HK) LimitedRm 1904A 19/F Lucky Commercial CentreNo. 103 Des Voeux Road WestHong Kong 999077ChinaRE: The country of origin of fiber optic patch cord assembliesDear Ms. Yang:In your letter dated
May 17, 2026
, you requested a country of origin ruling on fiber optic patch cordassemblies.The merchandise under consideration is described as fiber optic patch cord assemblies, identified by partnumbersX1A0002R0D08,FSPDAB11,FSPDAR11,NSDA.060611AA. The subject assemblies are further C described as fiber optic cables consisting of a fiber optic core, made of either 2 or 8 fibers depending on themodel number. The fiber core is enclosed within a jacket and the cable assembly is terminated at each endwith a fiber optic connector. The subject cable is used within various telecommunications industries totransfer optical data signals.In your request, you state the manufacturing process begins with the creation of the optical fibers in theUnited 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 anddiameter for the individual optic fiber. This fiber is then coated with protective polymer, trimmed at the ends,and tested for strength and function before it is exported to China. or VietnamIn China, the fiber core is colored, tested, and jacketed with plastic and aramid yarn. The cable is or Vietnamthen cut to length, and the ends are then prepared for the addition of the connectors. The connectors,originating in China are then assembled onto the ends in China or Vietnam, and the finished cable isinspected, tested and packaged for shipments to the U.S.When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether asubstantial 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 cable, it is the opinion of this office that the fiber coresmanufactured in the United States impart the character of the finished cables. Further, the assembly processperformed in China or Vietnam, including the addition of the covering and connectors, does not substantiallytransform the cores into new and different articles of commerce as their end use is predetermined and theyperform the primary function of transmitting the data signals. Based upon the facts presented, the origin ofX1A0002R0D08,FSPDAB11,FSPDAR11,NSDA.060611AA, willthe patch cord assembly, part number C 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 FTCDivision of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety ofproposed 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 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 Gary Chaffee at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division