RE: The country of origin of optical fiber cables

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364230 August 27, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Lynlee Brown Ernst & Young LLP 4365 Executive Dr. Suite 1600 San Diego, CA 92122 RE: The country of origin of optical fiber cables Dear Ms. Brown: In your letter dated August 12, 2026, you requested a country of origin ruling on behalf of your client, SEI Optifrontier Vietnam, Ltd. The merchandise under consideration is described as optical fiber cables, identified by their individual model numbers AN003870 (Model 1), AN003871 (Model 2), and AN003920 (Model 3). Models 1 and 2 are further described as in-rack fan-out (IRFO) cables, which allow a multi-fiber cable to be split at the optical fiber endpoints into individual connections. Model 3 is further described as a multi-drop (MD) cable, which is a single cable with optical fibers that are branched out along a cable route to serve multiple locations or devices along its path. All three models are for use within various telecommunications industries to transfer optical data signals. In your request, you state that the manufacturing process for all three optical fiber cable models begins in Japan with the production of the glass preform. This preform is heated and drawn into thin optical fiber strands with precise diameter and transmission characteristics. Protective and reinforcing materials, such as aramid yarn and flame-retardant PVC, are then applied to the fiber. Prior to export to Vietnam, Model 3 undergoes additional processing in Japan. Multiple cords are stranded—twisted together and secured with plastic tape—to create a bundled cable configuration. This is followed by a jacketing process, where an additional outer protective PVC layer is extruded over the stranded cords. This creates the integrated cable structure required for the MD configuration, providing enhanced mechanical protection and environmental resistance. In Vietnam, the cables are cut to the required lengths. The fiber ends are then processed, grouped in the required order, stripped, and inserted into the ferrule using adhesive. The ferrule and fiber then undergo polishing and surface inspection to ensure compliance with shape specifications and visual standards. Finally, connectors are assembled and secured to the cord via crimping and heating at both ends. The finished product is then bagged and packed into cartons or reels for export to the United States.
When determining the country of origin for purposes of applying current trade remedies under Section 301and 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 origin of the subject optical fiber cables, it is the opinion of this office that the fiber cores that are manufactured in Japan impart the character of the finished cables. Further, the assembly process performed in Vietnam, including the addition of connectors, does not substantially transform the optical cables 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 upon the facts presented, the origin of the optical fiber cables, model numbers AN003870, AN003871, and AN003920 will be Japan. 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