OT:RR:NC:N2:220
Ms. Cindy Yang
Adtek Industrial (HK) Limited
RM 1904A 19/F Lucky Commercial Centre
No. 103 Des Voeux Road West
Hong Kong 999077
China
RE: The country of origin of fiber optic patch cord assemblies
Dear Ms. Yang:
In your letter dated July 31, 2026, you requested a country of origin ruling.
The merchandise under consideration consists of two models of fiber optic patch cord assemblies, identified
by part numbers JLXQPLUTL and URGQWQWF8. These assemblies are described as fiber optic cables
comprising a fiber optic core of either 192 or 8 fibers, depending on the model. The fiber core is enclosed
within a jacket, and the cable assembly is terminated at each end with a fiber optic connector. These cables
are used within various telecommunications industries to transfer optical data signals.
In your request, you state that the manufacturing process begins with the creation of optical fibers in the
United States. This process commences with the melting and stretching of raw glass material into a glass bar.
This bar is then ground and cleaned before being further stretched and drawn to the appropriate length and
diameter for the individual optic fiber. The fiber is then coated with a protective polymer, trimmed at the
ends, and tested for strength and function before it is exported to China or Vietnam.
In China or Vietnam, the fiber core is colored, tested, and jacketed with plastic and aramid yarn. The cable is
then cut to length, and the ends are prepared for the addition of the connectors. The connectors, originating in
China, India, Japan, or the United States, are assembled onto the ends in China or Vietnam. Finally, the
finished cable is inspected, tested, and packaged for shipment 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 cables, it is the opinion of this office that the fiber cores
manufactured in the United States imparts the functional character of the finished cables. Furthermore, 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 continue to perform the primary function of transmitting optical data signals. Based
on the facts presented, the country of origin for the two models of patch cord assemblies, part numbers
JLXQPLUTL and URGQWQWF8, is the United States.
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