The country of origin of fiber optic cable assemblies

N351888 August 13, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Jennifer Tipping Global Trade Attorneys, LLC 2897 North Druid Hills Road NE, #185 Atlanta, GA 30329 RE: The country of origin of fiber optic cable assemblies Dear Ms. Tipping: In your letter dated July 31, 2025, you requested a country of origin ruling on behalf of your client, WCFO Communication, Ltd., Hong Kong. The five items at issue with this request are described as fiber optic cable assemblies. They are individually identified by the following model numbers: Item 1: 760259101 Item 2: UJGQXQXTN Item 3: UJXQZQZTM Item 4: JJGQPQPTP Item 5: JJXQVQVTP The subject cable assemblies are comprised of a fiber optic core, which consists of various individual optical fibers, ranging from 144 fibers to 288 fibers depending on the model number. This fiber core is enclosed within a jacket and each end of the cable has a specific optical connector. The subject cables are used within various telecommunications industries to transfer optical data signals. In your request, you state that the manufacturing process for all five items is substantially similar, with only slight differences in the location of certain steps. In all five cases, the process begins in the United States with the creation of the optical fiber. This begins with a raw glass preform being heated, melted, and drawn to the appropriate thickness. The optical fibers are coated with polymer and wound onto a spool. For items 1, 2, 4, and 5, the spool is then shipped to China where the fibers are wound in the appropriate configuration and encapsulated in insulation. This creates a cable which is then placed on a reel and shipped to Cambodia. In Cambodia, the cables are cut to length, and the optical connectors are assembled and attached to each end. The finished cables are then packaged and shipped to the U.S. For item 3, the spooled fiber is shipped directly from the U.S. to Cambodia. In Cambodia, the fibers are wound in the necessary configuration and then encapsulated with insulation. The optical connectors are then assembled and connected to each end. The finished cable is then packaged for shipment to the U.S. 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 cable assemblies, it is the opinion of this office that the optical fibers created in the U.S. impart the character of the finished articles. Further, all assembly processes performed in China and Cambodia do not substantially transform the individual fibers into new and different articles of commerce. Based upon the facts presented, the country of origin of the fiber optic cable assemblies, model numbers 760259101, UJGQXQXTN, UJXQZQZTM, JJGQPQPTP, and JJXQVQVTP, 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. 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, (for) James Forkan Acting Director National Commodity Specialist Division