OT:RR:NC:N2:220
Cindy Yang
ShenZhen ADTEK Technology Co., Ltd.
16/F, Building 1, Nanshan iPark Chongwen
No.3370 Liuxian Avenue, Nanshan District
Shenzhen 518000
China
RE: The country of origin of a patch cord assembly
Dear Ms. Yang:
In your letter dated January 26, 2026, you requested a country of origin ruling.
The merchandise under consideration is described as a fiber optic patch cord assembly, identified by part
number CX1A0008R5D07. The subject assembly is further described as a fiber optic cable consisting of a
fiber optic core, made of 12 fibers. The fiber core is enclosed within a jacket and the cable assembly is
terminated at each end with a fiber optic connector. The subject cable is used within various
telecommunications industries to transfer optical data signals.
In your request, you state the manufacturing process begins with the creation of the optical fibers 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 optic fiber. This fiber is then coated with protective polymer, trimmed at the ends,
and tested for strength and function before it is exported to China.
In China, the fiber core is colored, tested, and jacketed with plastic and aramid yarn. The cable is then cut to
length and the ends are then prepared for the addition of the connectors. The Chinese originating connectors
are then assembled onto the ends and the finished cable is inspected, tested and packaged for shipments 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, 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 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 patch cord
assembly, part number CX1A0008R5D07, 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 Gary Chaffee at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division