OT:RR:NC:N2:220
Darren Riley
Riley Trade Law PLLC
1701 Pennsylvania Ave NW, Suite 200 PMB 301
Washington, DC 20006
RE: The country of origin of RF Connectors and Adapters
Dear Mr. Riley:
In your letter dated July 20, 2026, you requested a country of origin ruling on behalf of your client, Cinch
Connectivity Solutions for RF Connectors and Adapters.
There are three RF connectors and one RF adapter under consideration in this request, which are individually
identified by part numbers 142-1701-871, 142-0901-401, 142-0701-506, and 142-0711-201. Part number
142-1701-871 is an RF connector comprised of an electrical contact, insulator, and connector body. Part
number 142-0901-401 is an RF adapter comprised of an electrical contact, insulator, connector body, lock
washer, and nut. Part number 142-0701-506 is an RF connector comprised of an electrical contact, long
insulator, connector body, solder washer, base, short insulator, lock washer, and nut. Part number
142-0711-201 is an RF connector comprised of an electrical contact, insulator, and connector body. All four
items are assembled in Mexico of goods imported from China, the U.S., or Switzerland.
RF connectors and adapters are typically used in telecommunications, broadcast technology, or test
equipment to link coaxial cables to electronic devices via surface mount technology for the transfer of
high-frequency signals where they are designed to maintain electrical shielding and prevent power loss.
Classification
While classification was not requested, the classification of the RF connectors and adapters must be
determined in order to apply the tariff-shift rule.
Based on the information provide in the request, the applicable subheading for the RF connectors and
adapters will be 8536.69.4040, Harmonized Tariff Schedule of the Untied States (HTSUS), which provides
for “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in
electrical circuits…for a voltage not exceeding 1,000V: Lamp-holders, plugs and sockets: Other: Coaxial
connectors; cylindrical multicontact connectors; rack and panel connectors; printed circuit connectors; ribbon
or flat cable connectors: Printed circuit connectors.” The general rate of duty will be free.
Origin
With respect to origin, all four part numbers are globally sourced products, integrating components from
numerous countries to create a finished electrical connector or adapter. For part number 142-1701-871, the
connector body is from the U.S. and the electrical contact and insulator are from China. For part number
142-0901-401, the electrical contact is from the U.S., and all other components are from China. For part
number 142-0701-506, the electrical contact is from Switzerland, and all other components are from China
and the U.S. For part number 142-0711-201, all components, including the electrical contact are from China.
The assembly process occurs in Mexico and is generally the same for all four part numbers. The assembly
process for the connector begins with the electrical contact being inserted into the insulator. This
subassembly is then inserted into the connector body. Both steps require a specialized tool to combine these
three parts to form a connector or adapter. For models that include washers and nuts, these components are
added to form the finished good.
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 country of origin of the subject connectors and adapters, it is the opinion of this office that the
electrical contact imparts the character of the finished connectors as it is the functional component of the
connector. Further, the addition of an insulator, connector body and other components does not substantially
transform the electrical contact into a new and different article of commerce with a name, character, and use
distinct from the individual components. Based upon the facts provided, the origin of part numbers
142-1701-871 and 142-0711-201 will be China, part number 142-0701-506 will be Switzerland, and part
number 142-0901-401 will be U.S.
USMCA Eligibility
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note ("GN")
11 of the HTSUS implements the USMCA. GN 11(b) sets forth the criteria for determining whether a good is
an originating good for purposes of the USMCA. GN 11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential
tariff treatment provided for in the applicable subheading and quantitative limitations set forth in the
tariff schedule as a "good originating in the territory of a USMCA country" only if-
(i) the good is a good wholly obtained or produced entirely in the territory of one or more
USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries,
exclusively from originating materials;
(iii) the good is a good produced entirely in the territory of one or more USMCA countries
using non-originating materials, if the good satisfies all applicable requirements set forth in
this note (including the provisions of subdivision (o));
Since the subject connectors and adapters contain non-originating components, they are not considered goods
wholly obtained or produced entirely in a USMCA country under GN 11(b)(i), nor are the products produced
exclusively from originating materials per GN 11(b)(ii). Therefore, we must determine whether the
non-originating materials undergo the tariff shift and other requirements provided for in GN 11(b)(iii) and
GN 11(o). The applicable tariff shift rule for goods classified under subheading 8536.69, HTSUS, states, in
relevant part:
86. (A) A change to subheadings 8536.61 through 8536.69 from any other heading, except from tariff
items 8538.90.10, 8538.90.30 or 8538.90.60
Based on the facts provided, the goods described above qualify for USMCA preferential tariff treatment,
because they will meet the requirements of HTSUS General Note 11(b)(iii) and GN 11(o). The goods will be
eligible for preferential treatment under the USMCA upon compliance with all applicable laws, regulations,
and agreements.
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 P. Forkan
Director
National Commodity Specialist Division