The country of origin of RF Connectors and Adapters

N363463
August 7, 2026
OT:RR:NC:N2:220
CATEGORY: Origin Darren Riley Riley Trade Law PLLC 1701 Pennsylvania Ave NW, Suite 200 PMB 301 Washington, DC 20006 RE: The country of origin of RF Connectors and Adapters Dear Mr. Riley: In your letter dated July 20, 2026, you requested a country of origin ruling on behalf of your client, Cinch Connectivity Solutions for RF Connectors and Adapters. There are three RF connectors and one RF adapter under consideration in this request, which are individually identified by part numbers 142-1701-871, 142-0901-401, 142-0701-506, and 142-0711-201. Part number 142-1701-871 is an RF connector comprised of an electrical contact, insulator, and connector body. Part number 142-0901-401 is an RF adapter comprised of an electrical contact, insulator, connector body, lock washer, and nut. Part number 142-0701-506 is an RF connector comprised of an electrical contact, long insulator, connector body, solder washer, base, short insulator, lock washer, and nut. Part number 142-0711-201 is an RF connector comprised of an electrical contact, insulator, and connector body. All four items are assembled in Mexico of goods imported from China, the U.S., or Switzerland. RF connectors and adapters are typically used in telecommunications, broadcast technology, or test equipment to link coaxial cables to electronic devices via surface mount technology for the transfer of high-frequency signals where they are designed to maintain electrical shielding and prevent power loss. Classification While classification was not requested, the classification of the RF connectors and adapters must be determined in order to apply the tariff-shift rule. Based on the information provide in the request, the applicable subheading for the RF connectors and adapters will be 8536.69.4040, Harmonized Tariff Schedule of the Untied States (HTSUS), which provides for “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits…for a voltage not exceeding 1,000V: Lamp-holders, plugs and sockets: Other: Coaxial connectors; cylindrical multicontact connectors; rack and panel connectors; printed circuit connectors; ribbon or flat cable connectors: Printed circuit connectors.” The general rate of duty will be free.

Origin With respect to origin, all four part numbers are globally sourced products, integrating components from numerous countries to create a finished electrical connector or adapter. For part number 142-1701-871, the connector body is from the U.S. and the electrical contact and insulator are from China. For part number 142-0901-401, the electrical contact is from the U.S., and all other components are from China. For part number 142-0701-506, the electrical contact is from Switzerland, and all other components are from China and the U.S. For part number 142-0711-201, all components, including the electrical contact are from China. The assembly process occurs in Mexico and is generally the same for all four part numbers. The assembly process for the connector begins with the electrical contact being inserted into the insulator. This subassembly is then inserted into the connector body. Both steps require a specialized tool to combine these three parts to form a connector or adapter. For models that include washers and nuts, these components are added to form the finished good. 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 country of origin of the subject connectors and adapters, it is the opinion of this office that the electrical contact imparts the character of the finished connectors as it is the functional component of the connector. Further, the addition of an insulator, connector body and other components does not substantially transform the electrical contact into a new and different article of commerce with a name, character, and use distinct from the individual components. Based upon the facts provided, the origin of part numbers 142-1701-871 and 142-0711-201 will be China, part number 142-0701-506 will be Switzerland, and part number 142-0901-401 will be U.S. USMCA Eligibility The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30, 2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN") 11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN 11(b) states: For the purposes of this note, a good imported into the customs territory of the United States from the territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule as a "good originating in the territory of a USMCA country" only if- (i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries; (ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from originating materials;

(iii) the good is a good produced entirely in the territory of one or more USMCA countries using non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the provisions of subdivision (o)); Since the subject connectors and adapters contain non-originating components, they are not considered goods wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced exclusively from originating materials per GN 11(b)(ii). Therefore, we must determine whether the non-originating materials undergo the tariff shift and other requirements provided for in GN 11(b)(iii) and GN 11(o). The applicable tariff shift rule for goods classified under subheading 8536.69, HTSUS, states, in relevant part: 86. (A) A change to subheadings 8536.61 through 8536.69 from any other heading, except from tariff items 8538.90.10, 8538.90.30 or 8538.90.60 Based on the facts provided, the goods described above qualify for USMCA preferential tariff treatment, because they will meet the requirements of HTSUS General Note 11(b)(iii) and GN 11(o). The goods will be eligible for preferential treatment under the USMCA upon compliance with all applicable laws, regulations, and agreements. 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