The country of origin of fiber optic patch cord assemblies

N363893August 11, 2026OT:RR:NC:N2:220
CATEGORY: OriginMs. Cindy 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
July 31, 2026
, you requested a country of origin ruling.The merchandise under consideration consists of two models of fiber optic patch cord assemblies, identifiedby part numbers JLXQPLUTL and URGQWQWF8. These assemblies are described as fiber optic cablescomprising a fiber optic core of either 192 or 8 fibers, depending on the model. The fiber core is enclosedwithin a jacket, and the cable assembly is terminated at each end with a fiber optic connector. These cablesare used within various telecommunications industries to transfer optical data signals.In your request, you state that the manufacturing process begins with the creation of optical fibers in theUnited States. This process commences with the melting and stretching of raw glass material into a glass bar.This bar is then ground and cleaned before being further stretched and drawn to the appropriate length anddiameter for the individual optic fiber. The fiber is then coated with a protective polymer, trimmed at theends, 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 isthen cut to length, and the ends are prepared for the addition of the connectors. The connectors,riginating in oChina, India, Japan, or the United Statesare assembled onto the ends in China or Vietnam. Finally, 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 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 cables, it is the opinion of this office that the fiber coresmanufactured in the United States impart the f character of the finished cables. Furthermore, thesunctionalassembly 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 ispredetermined and they continue to perform the primary function of transmitting optical data signals. Basedon the facts presented, the country of origin for the two models of patch cord assemblies, part numbersJLXQPLUTL and URGQWQWF8, is the United States.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