OT:RR:NC:N2:212
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin of fiber optic terminal boxes
Dear Ms. Murrin:
In your letter dated August 29, 2025, you requested a country of origin ruling on behalf of your client,
Shenzhen ADTEK Technology Company, Ltd.
The merchandise at issue with this request is described as five models of fiber optic terminal box assemblies,
which are individually identified by part numbers FPP-TN-K-D1, FPP-TN-Z-D2, FPP-TN-A-D3,
FPP-TN-A-86-V4, and FPP-TN-C3-SAB. The subject devices consist of a fiber optic patch cord assembly, or
jumper, attached to a splitter module within a plastic enclosure. The terminal boxes are used to provide fiber
optic network connections within commercial and private installations.
In your request, you state that the manufacturing process for all five models is the same and begins with the
creation of the optical fiber in the United States. This process includes the glass raw materials being treated,
melted, and drawn through various stages until the fiber reaches the appropriate diameter. This fiber is then
coated with polymer before it is trimmed and tested for functionality. The finished fiber is then sent to China.
In China, the fiber is cut to length, colored, and jacketed prior to the connectors being added to the ends. This
completes the jumper assembly, which is then coiled onto a splice tray and the splitter modules are added.
This assembly is then enclosed within the plastic box with mounting hardware prior to the finished device
being tested and packaged for shipment to the United States.
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 terminal boxes, it is the opinion of this office that the jumper assembly, which is
manufactured using U.S. origin optical fibers, imparts the character of the finished device. Further, the U.S.
originating fiber is the essential transmission component of not just the jumper assembly, but the completed
box. The assembly process performed in China is not significantly complex in order to transform the US
components into new and different articles of commerce. Based upon the facts presented, the country of
origin of the fiber optic terminal boxes, part numbers FPP-TN-K-D1, FPP-TN-Z-D2, FPP-TN-A-D3,
FPP-TN-A-86-V4, and FPP-TN-C3-SAB, is 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)
Denise Faingar
Acting Director
National Commodity Specialist Division