OT:RR:NC:N2:220
Cindy Yang
ADTEK Industrial (HK) Limited
RM 1904A 19/F Lucky Commercial Centre, No. 103 Des Voeux Road West
Hong Kong 1904A
China
RE: The country of origin of a fiber optic patch cord assembly
Dear Ms. Yang:
In your letter dated March 4, 2026, you requested a country of origin ruling on a fiber optic patch cord
assembly.
The merchandise under consideration is described as a fiber optic patch cord assembly, part number
CX1A0002R0D05. The subject assembly is further described as a fiber optic cable consisting of a fiber optic
core made of 2 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 aramid yarn or other plastic. The cable is then cut
to length, and the ends are then prepared for the addition of the connectors. The connectors, originating in
China, are then assembled onto the ends in China or Vietnam, and the finished cable is inspected, tested and
packaged for shipments to the U.S.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) 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 or Vietnam, 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 CX1A0002R0D05, 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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division