The country of origin of fiber optic cable assemblies

N356243 December 5, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Alexis Kwak Clearfield 7050 Winnetka Ave North, Suite 100 Brooklyn Park, MN 55428 RE: The country of origin of fiber optic cable assemblies Dear Ms. Kwak: In your letter dated November 19, 2025, you requested a country of origin ruling. The merchandise under consideration is described as five models of fiber optic cable assemblies, identified by part numbers PA1-001-CZB-CZB, PA1-002-EZB-EZB, PA1-001-CZD-ZZD, PA1-002-EZB-JZB, and PA1-001-CZB-ZZB. The cable assemblies are composed of fiber optic cables terminated with optical connectors on each end. The number of cables and connectors varies according to the specific model and configuration. The subject cable assemblies provide fiber optic network connection within commercial or private installations such as data centers. The manufacturing process begins in China using the optical fibers that are fully manufactured in the United States. The optical fibers are sent to China on reels where they are jacketed via the extrusion process. The jacketed cables are spooled and shipped to Vietnam for further processing. In Vietnam, the jacketed cables are cut to specific lengths depending on the model and fitted with appropriate optical connectors. The finished fiber optic cables are then tested and packaged for shipment to the United States. 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 cable assemblies, it is the opinion of this office that the optical fibers manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China and Vietnam, including jacketing and fitting of connectors, does not substantially transform the optical fibers 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 country of origin for the fiber optic cable assemblies, part numbers PA1-001-CZB-CZB, PA1-002-EZB-EZB, PA1-001-CZD-ZZD, PA1-002-EZB-JZB, and PA1-001-CZB-ZZB, 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division