OT:RR:NC:N2:212
Crystal Yang
ShenZhen ADTEK Technology Co., Ltd.
16/F, Building 1, Nanshan, iPark Chongwen
Shenzhen 518000
China
RE: The country of origin of fiber optic terminal boxes
Dear Ms. Yang:
In your letter dated November 11, 2025, you requested a country of origin ruling.
The merchandise under consideration is described as three models of a Fiber Optic Terminal Box,
individually identified by part numbers FPP-H-SAB-KRI3, FPP-H-SAB-NKHI3, and FPP-TN-C3-BP. The
subject devices consist of a fiber optic patch cord assembly, also referred to as a jumper, attached to a splitter
module and enclosed within a plastic box. The subject assemblies function identically and are used to provide
fiber optic network connection within a commercial or private installation.
In your request, you state that the manufacturing process for all three models is identical 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. The 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, colored and jacketed prior to the addition of the necessary
connectors. This completes the jumper assembly, which is then coiled onto a splice tray and the splitter
modules are added. The device is then completed by being placed within the plastic enclosure 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 terminal boxes, it is the opinion of this office that the jumper assemblies,
which incorporate U.S. origin optical fibers, impart the character of the finished device. Further, the assembly
process performed to manufacture the finished product in China is not significantly complex to substantially
transform the optical jumper assemblies. As the jumper assemblies would be considered U.S. origin, the
county of origin of the finished Fiber Optic Terminal Boxes, part numbers FPP-H-SAB-KRI3,
FPP-H-SAB-NKHI3, and FPP-TN-C3-BP, would 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division