OT:RR:NC:N2:209
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin of OSFP transceiver modules
Dear Ms. Murrin:
In your letter dated February 3, 2026, you requested a country of origin ruling on behalf of your client
Accelink Technologies, for Octal Small Form Factor Pluggable transceiver modules.
The item concerned is referred to as the 800G Octal Small Form Factor Pluggable (OSFP) DR8 transceiver
module. This is a transceiver that will be mounted on each end of a length of fiber optic cable. The subject
merchandise is a hot-pluggable module that plugs into network devices, such as switches in data centers. It is
used to convert an electrical signal into an optical signal, and conversely an optical signal back into electrical
signal. These transceivers are designed for use in 800 Gigabit Ethernet links on up to 500m of single mode
fiber. They are used in networking and data communications sectors in order to receive, convert, and transmit
different signals.
The main components of the OSFP transceiver are the printed circuit board assembly (PCBA), the optical
subassembly (OSA), and the transceiver housing.
OSA (China-Origin):
The OSA includes both a transmit optical subassembly (TOSA) and a receive optical subassembly (ROSA).
The TOSA and ROSA are referred to as a transmitter (Tx) and receiver (Rx).
The Tx part of the OSA is responsible for converting the electrical signals into optical signals and
transmitting these signals over an optical fiber strand in the fiber array (FA). It uses a laser diode to generate
and focus a light beam into a Silicon Photonic (SiPho) integrated circuit. The photonic integrated circuit
splits the light signal into four light beams. An electrical signal from the main PCBA is used to modulate the
four light beams which are then launched into the optical fibers of the FA via the isolator focus optics. The
Tx part of the OSA is manufactured in China and attached to the Malaysia-origin PCBA in China.
The Rx part of the OSA is responsible for receiving the optical signals transmitted from the Tx and
converting them back to electrical signals so that the communication equipment can understand them. The Rx
part of the OSA consists of an Rx block, four photodiodes, two single-layer capacitors, and a transimpedance
amplifier. The Rx part of the OSA each receives four light beams from optical fibers and sends them to four
photodiodes. It is the photodiodes that convert the light signals into electrical signals which are then
amplified by the transimpedance amplifier on the PCBA. The Rx part of OSA is manufactured in China and
attached to the Malaysia-origin PCBA in China.
Main Board PCBA (Malaysia-origin)
The Main Board PCBA contains approximately 560 electrical elements sourced from various countries of
origin. The main electrical element on the PCBA is the digital signal processor (DSP) chip of U.S.-origin.
This is the highest value item on the BOM and a critical component of the PCBA. The Main Board PCBA is
the foundation of the transceiver and imparts its essence. Without the Main Board PCBA, the Tx part of the
OSA cannot generate optical signals and the Rx part of the OSA cannot convert optical signals into electrical
signals
The DSP provides for signal amplification, detection, regeneration, and reconditioning. The DSP works with
the OSA and provides electrical driving signals for the OSA (both the Tx and Rx). The DSP signals the laser
diode of the Tx side of the OSA to emit optical signals into the fiber array and out of the transceivers. The
DSP also processes optical signals from the fiber array into the transceiver on the Rx side of the OSA. The
signal is not readable by the OSA until it is formatted by the DSP chips. On the receiving side, when the
optical transceiver receives a signal from the OSA and converts the optical signal to electrical signal, the
electrical signal is not readable by the optical transceiver until it undergoes further processing from the DSP.
The Main Board PCBA also contains an erasable programmable read-only memory chip (EPROM) that will
be programmed in Malaysia to provide the required instructions to perform the transceiver function. The
EPROM information is saved in the flash memory of the MCU IC (Accelink PCBA Part Number 20719401
on the BOM). More than three-fourths of the total components of the transceiver are on the Main Board
PCBA.
Manufacturing of the Main Board PCBA in Malaysia:
Production in Malaysia includes the creation of the PCBA via surface mount technology (SMT). The PCBA
consists of numerous components/elements from various countries of origin. The SMT process is a
multistage process requiring different types of specialized machines. The SMT process for the PCBA is as
follows:
1. Solder paste printing.
2. Solder paste inspection (SPI).
3. SMT by means of a pick-and-place machine is used to populate the board with approximately 560
dedicated PCBA components.
4. Solder reflow to permanently adhere the components to the board.
5. Optical inspection (AOI).
6. Automated 3D x-ray inspection.
7. Another round of the SMT subprocess, repeating all previous steps.
8. Conformal coating in order to protect the PCBA and its components. The coating is then dried and
baked.
9. Manual visual inspection via microscope.
Once the PCBA is assembled, it is sent to China where the OSA is attached.
Manufacturing Steps in China: Attaching the OSA to the PCBA
1. Receive PCBA from Malaysia.
2. Attach the SiPo, laser diode, and substrate onto PCBA.
3. Perform wire bonding.
4. Attach the isolator to the PCBA with epoxy curing.
5. Attach and align Lens 1 to the PCBA with epoxy curing.
6. Attach and align Lens 2 to the PCBA with epoxy curing.
7. Attach and align the Tx Fiber Array with epoxy curing.
8. Rx FA alignment and attach with epoxy curing.
9. Attach a cover to protect the OSA on PCBA.
10. Test and inspect the OSA-on-PCBA.
The OSA-on-PCBA is then returned to Malaysia where it is assembled into the finished transceiver.
Final Assembly in Malaysia:
Once the OSA-on-PCBA arrives back in the Malaysia, thermal grease is added to the light source in order to
ensure heat dissipation and a component for heat release is attached to the light source. Next, an OSA cover
is attached to the OSA via a UV curing and baking process. Next, the fiber router is attached, which routes
fibers between the Tx part of the OSA subassembly, the Rx part of OSA subassembly, and the fiber
connectors. Lastly, thermal pads are attached to allow the entire optical transceiver to dissipate heat. Once the
above manufacturing in Malaysia is completed, the mechanical housing is attached to the parts, the software
is loaded, and the transceiver undergoes electrical and optical performance tuning, testing, and quality
assurance.
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).
Based upon the facts presented, it is the opinion of this office that the manufacturing processes that take place
within Malaysia to create the main PCBA is both substantial and complex. The character of this product is
imparted by the main PCBA which would be considered the dominant component of this assembly. The
assembly/manufacturing process that takes place in China does not change the end use of the main PCBA.
The PCBA does not undergo a substantial transformation as a result of the Chinese processing. Therefore,
since a substantial transformation does not occur as a result of the Chinese processing, the country of origin
of this product would be Malaysia upon importation into the United States and as such, the Section 301 trade
remedy would not be applicable.
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 Steven Pollichino at [email protected].
Sincerely,
(for)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division