OT:RR:NC:N2:212
Sarah Li
Shenzhen ADTEK Technology Co., Ltd.
5F, Block B, Dakan Science & Technology Park, Xili Nanshan
Shenzhen 518055
China
RE: The country of origin of patch cord assemblies
Dear Ms. Li:
In your letter dated June 5, 2025, you requested a country of origin ruling.
The merchandise under consideration is described as five models of a fiber optic patch cord assembly,
identified by part numbers UQXQVQVF8, 92-00008, 92-00011, GG8BS11DRE, and GG16S11DRE. The
subject assemblies are further described as fiber optic cables that consist of a fiber optic core, which consists
of 8, 16, 12, or 32 optical fibers depending on the model number. The fibers are enclosed within a jacket and
are terminated with a single connector at one end and fanned out to various optical connectors at the other.
The subject cables are used within various telecommunications industries to transfer optical data signals.
In your request, you state that the manufacturing process for all 5 parts is substantially similar and begins
with the creation of the optical fiber 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 optical fiber. This fiber is then coated with
polymer and tested for strength and function before it is exported to China.
In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and
prepared for the addition of the connectors, which are sourced from China. The connectors are then
assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S.
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 origin of the subject fiber optic cable assemblies, 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, including the addition of the covering and connectors, does not substantially
transform the cores into new and different articles of commerce. Based upon the facts presented, the origin of
the fiber optic patch cord assembly, part numbers UQXQVQVF8, 92-00008, 92-00011, GG8BS11DRE, and
GG16S11DRE, will 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 FTC
Division of Enforcement, 6th and Pennsylvania Avenue, N.W., Washington, D.C. 20508 on the propriety of
proposed 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 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 Luke LePage at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division