The country of origin of fiber optic assemblies

N356949 January 7, 2026 OT:RR:NC:N2:212 CATEGORY: Origin Christina Leonard Sandler, Travis & Rosenberg, P.A. 286 Madison Avenue - Suite 1200 New York, NY 10017 RE: The country of origin of fiber optic assemblies Dear Ms. Leonard: In your letter dated December 11, 2025, you requested a country of origin ruling on behalf of your client, Aachen SV Technology Development Company Ltd. There are four items at issue with this request, which are various versions of fiber optic assemblies and are individually identified as follows: Harness, Model Number CU6AH Fanout Trunk, Model Number CU6AF Hydra Product, Model Number CU6AY Patchcord, Model Number CU6AP All four items are comprised of a bundle of optical fibers, the number dependent upon the model and needs of the customer, covered with PVC and terminated with various optical connectors at the ends. The number of connectors is also dependent upon the needs of the customer. The cables are used for various telecommunications and data communication applications. In your request, you state that the manufacturing process for all four assemblies is substantially similar and begins with the creation of the optical preform in the United States by depositing silica particles onto a base rod or substrate tube. The preform is then drawn into the specific fiber in either the U.S., India, or China. The optical fiber is then sent to Vietnam. In Vietnam, the optical fibers are bundled into the appropriate configuration, colored and jacketed with PVC and cut to the desired length. The connectors are then added to the ends before the finished assemblies are packaged 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 assemblies, it is the opinion of this office that the preforms are manufactured with specific attributes and qualities that are predetermined by the materials used to create the preforms. The drawing of the individual fibers will preserve the key properties of the preform such as the refractive index, core and cladding structure, and chemical composition. The drawing process merely transforms the physical attributes by reducing the diameter into thin fibers. Further, the drawing process, when performed in a China or India, as well as the final assembly process taking place in Vietnam, including jacketing of the optical fibers and addition of connectors, do not substantially transform the preform into new and different articles of commerce. Accordingly, based upon the facts presented, the country of origin of the below listed fiber optic assemblies will be the United States. Harness, Model Number CU6AH Fanout Trunk, Model Number CU6AF Hydra Product, Model Number CU6AY Patchcord, Model Number CU6AP 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division