The country of origin of fiber optic patch cord assemblies

N363319
August 6, 2026
OT:RR:NC:N2:220
CATEGORY: Origin Ms. Cindy Yang ADTEK Industrial (HK) Limited Rm 1904A 19/F Lucky Commercial Centre No. 103 Des Voeux Road West Hong Kong 999077 China RE: The country of origin of fiber optic patch cord assemblies Dear Ms. Yang: In your letter dated July 15, 2026, you requested a country of origin ruling on fiber optic patch cord assemblies. The merchandise under consideration is described as five models of fiber optic patch cord assemblies, identified by part numbers HGGQWQWTM, HGGQYQYTM, LAJGQYQWTM, LUJGQYQYTM, and CX1A0008R6B30. The subject assemblies are further described as fiber optic cables consisting of a fiber optic core, made of 144 fibers or 8 fibers, depending on the model number. 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 the manufacturing process begins with the creation of optical fibers 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 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 Vietnam. In China or Vietnam, the fiber core is colored, tested, and jacketed with plastic and aramid yarn. The cable is then cut to length, and the ends are then prepared for the addition of the connectors. The connectors, originating in China, India, Japan, or the United States, are then assembled onto the ends in China or Vietnam, and the finished cable is inspected, tested and packaged for shipment 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 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 or Vietnam, 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 on the facts presented, the origin of the five models of patch cord assemblies, part numbers HGGQWQWTM, HGGQYQYTM, LAJGQYQWTM, LUJGQYQYTM, and CX1A0008R6B30, will be the United States. 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 Gary Chaffee at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division