The country of origin of fiber optic terminal boxes

N359671 April 6, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Crystal Yang ADTEK Industrial (HK) Limited RM 1904A 19/F Lucky Commercial Centre, No. 103 Des Voeux Road West Hong Kong China RE: The country of origin of fiber optic terminal boxes Dear Ms. Yang: In your letter dated March 12, 2026, you requested a country of origin ruling for fiber optic terminal boxes. In lieu of a sample, photographs were submitted with your request. The merchandise under consideration is described as two models of fiber optic terminal boxes, identified as model numbers FPP-TN-A-86 and FPP-TN-E-85. The subject terminal boxes consist of a fiber optic patch cord assembly, or jumper, attached to a splitter module within a plastic enclosure. The terminal boxes are used to provide fiber optic network connections within commercial and private installations. In your request, it is stated that the manufacturing process for both models is the same. The process begins in the United States, where the optical fiber is created. This process includes the glass raw materials being treated, melted, and drawn through various stages until the fiber reaches the appropriate diameter. The fiber is then coated with polymer before it is trimmed and tested for functionality. The finished fiber is then sent to China. In China or Vietnam, the fiber is cut to length, colored, and jacketed with aramid yarn and PVC plastic. The fiber then is shipped to another factory in China or Vietnam where Chinese origin connectors are added to the ends. This completed jumper assembly is then coiled onto a splice tray, and the splitter modules are added onto the fiber, dividing a single incoming light signal into multiple output signals. The assembly is then enclosed within the plastic box with mounting hardware. The finished terminal box is tested and packaged for export 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 terminal boxes, it is the opinion of this office that the jumper assembly, which is manufactured using U.S. origin optical fibers, imparts the essential character of the finished device. Further, the U.S. originating fiber is the essential transmission component of not just the jumper assembly, but the completed terminal box. The assembly process performed in China is not significantly complex in order to transform the U.S. components into new and different articles of commerce. Based on the facts presented, the country of origin of the fiber optic terminal boxes, model numbers FPP-TN-A-86 and FPP-TN-E-85, is 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 Code of Federal Regulations (19 CFR 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 Michael Capanna michael.s.capanna@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division