The country of origin of fiber optic cable assemblies

N356350 December 4, 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 November 21, 2025, you requested a country of origin ruling on behalf of your client, WCFO Communication, Ltd. The four items at issue with this request are described as fiber optic cable assemblies used within various telecommunications industries to transfer optical data signals. The assemblies are individually identified and described as follows: Item number MQGQW2QW28R is comprised of 16 individual optical fibers within a core, which is surrounded by aramid yarn for strength and further covered with plastic sheeting material. Each end is terminated with an optical fiber connector. Item number JJGQPQPTN is comprised of 24 bunches of optical fiber, each bunch containing 8 individual optical fibers. The bunches are surrounded by aramid yarn and further covered with nonconductive protection material. Each end of the cable has multiple fiber optic connectors. Item number HJGRPRP3M is comprised of 9 bunches of optical fiber, each containing 16 individual optical fibers. The bunches are surrounded by aramid yarn and further covered with nonconductive protection material. Each end of the cable has multiple fiber optic connectors. Item number GSRGRWQW7R is comprised of 16 individual optical fibers within a core, which is surrounded by aramid yarn for strength and further covered with plastic sheeting material. One end of the cable is terminated with a single fiber optic connector while the other has two. In your request, you state that the manufacturing process for all four items begins with the creation of the optical fiber in the United States. In the U.S., a raw glass preform is created and then heated, melted, and drawn to the appropriate thickness. This drawn fiber is then coated with polymer before it is wound onto a reel and shipped to Cambodia. In Cambodia, the individual fibers are wound into the appropriate configuration and the yarn and coating is added to create the fiber core. When necessary, the cores are bunched together and further encapsulated in a covering. The connectors are then assembled onto the ends of the cable before the finished cable is 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 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 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, item numbers MQGQW2QW28R, JJGQPQPTN, HJGRPRP3M, and GSRGRWQW7R, 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division