The country of origin of fiber optic cables

N351372 July 28, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Adrian Estrada Clearfield, Inc 7050 Winnetka Ave N Brooklyn Park, MN 55428 RE: The country of origin of fiber optic cables Dear Mr. Estrada: In your letter dated July 15, 2025, you requested a country of origin ruling. There are two items at issue with this request, which are described as fiber optic cable assemblies. The first is identified as the Pushable FieldShield and is further specifically represented by the below item numbers: FS-CA1-001-8ZD FS-CA1-002-8ZD FS-CA1-006-8ZD FS-CA1-012-8ZD FS-CC1-001-8ZD These assemblies are comprised of a fiber optic core consisting of 1 to 12 fibers, depending on the model. This core is jacketed in plastic and imported on reels without connectors at either end. The subject cables are used within various telecommunications industries and installations to transfer optical data signals. The second item is identified as the FLEXdrop cable and further specifically represented by the below item numbers: FS-CP1-001-8ZD FS-CP1-001-6ZD These assemblies are comprised of a single fiber optic core, which is individually wrapped in a protective Low Smoke Zero Halogen (LSZH) buffering layer. The core is further jacketed in plastic and imported on reels without connectors at either end. The subject cables are used within various telecommunications industries and installations to transfer optical data signals. In your request, you state that the manufacturing process for all items at issue is substantially similar. This process begins with pre-colored, U.S.-origin optical fibers being imported into Finland. For those cables that are comprised of multiple fibers, the fibers are bundled together in the appropriate configuration. Kevlar strength members are then added prior to plastic jacketing being extruded around the core to complete the cable. The cable is then placed on a reel in preparation for shipment to the United States. 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 cables, it is the opinion of this office that the U.S. origin fibers impart the character of the finished articles. Further, any process performed in Finland is simple in nature and does not substantially transform the fibers into new and different articles of commerce. Based upon the facts presented, the country of origin of the Pushable Fieldshield cables and the FLEXdrop cables, identified by the model numbers listed below, is the United States. FS-CA1-001-8ZD FS-CA1-002-8ZD FS-CA1-006-8ZD FS-CA1-012-8ZD FS-CC1-001-8ZD FS-CP1-001-8ZD FS-CP1-001-6ZD 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, James Forkan Acting Director National Commodity Specialist Division