CLA-2-85:OT:RR:NC:N2:212
Sa Ung Kim
SEIN Customs & Auditing Corp
138, Seoun-ro, Secho-gu,
Seoul 06619
South Korea
RE: The tariff classification and eligibility of the United States-Korea Free Trade Agreement (UKFTA) of
fiber optic cables
Dear Sa Ung Kim:
In your letter dated December 9, 2025, you requested a binding ruling on the tariff classification and
eligibility of fiber optic cables under the United States-Korea Free Trade Agreement (UKFTA), on behalf of
your client Mercury Fiber Optics.
The merchandise under consideration is identified by model number LAC LT-041 DRY SJSA 288F G652D
PP TUBE MDPE JKT and described as an insulated fiber optic cable. The subject cable consists of twelve
optical fiber bundles surrounding a central strength member, the entirety of which is encased in tape and an
outer jacket. The cable is imported on reels and is not terminated with connectors. The subject cable is used
to transmit optical data signals in various communication networks, telecommunications facilities, data
centers, and building network wiring.
In your request, you state that the manufacturing process begins with the creation of the optical preform in
Japan. This preform is then sent to Korea where it is fed into a high temperature furnace, which allows for the
optical fiber to be drawn to the appropriate thickness. This fiber is then cooled before various levels of
protective coating and colors are added. The fibers are then extruded with resin before they are bundled into
the tube structure. These tubes are then stranded around the internal strength member before the outer jacket
and sheath is added to surround the finished cable. The finished cable is then wound onto a reel and prepared
for shipment to the United States.
Classification:
In your request, you suggest that the correct classification for the subject fiber optic cable is under
subheading 8544.70, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the fiber optic cable, model number LAC LT-041 DRY SJSA 288F G652D PP
TUBE MDPE JKT, will be 8544.70.0000, HTSUS, which provides for “Insulated (including enameled or
anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted
with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with
electric conductors or fitted with connectors: Optical Fiber cables.” The general rate of duty will be free.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience
and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided
at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
UKFTA:
General Note 33, HTSUS, sets forth the criteria for determining whether a good is originating under the
United States-Korea Free Trade Agreement (UKFTA). General Note 33(b), HTSUS, (19 USC 1202) states
that:
For the purposes of this note, subject to the provisions of subdivisions (c), (d), (n) and (o) thereof, a good
imported into the customs territory of the United States is eligible for treatment as an originating good of a
UKFTA country under the terms of this note if-
(i) the good is wholly obtained or produced entirely in the territory of Korea or of the United States,
or both;
(ii) the good is produced entirely in the territory of Korea or of the United States or both, and –
(A) each of the nonoriginating materials used in the production of the good undergoes an
applicable change in tariff classification specified in subdivision (o) of this note; or
(B) the good otherwise satisfies any applicable regional value-content or other requirements
set forth in such subdivision (o); and satisfies all other applicable requirements of this note and
of applicable regulations; or
(iii) the good is produced entirely in the territory of Korea or the United States,
or both, exclusively from materials described in subdivisions (i) or (ii), above.
For goods classified under subheading 8544.70, HTSUS, General Note 33(o) states:
95. A change to subheading 8544.70 from any other subheading.
Based upon the information provided, the Japanese optical preform is the only non-originating material used
in the Korean manufacturing process. As this is clearly classified outside of the relevant subheading in the
note above, it would make the aforementioned tariff shift. Consequently, based upon the facts presented the
subject fiber optic cables would be eligible for preferential tariff treatment under the UKFTA.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division