The country of origin of optical imaging fiber bundles

N359683 April 2, 2026 OT:RR:NC:N2:220 CATEGORY: Origin Paula Connelly Sandler Travis & Rosenberg, P.A. 100 Trade Center, Suite G-700 Woburn, MA 01801 RE: The country of origin of optical imaging fiber bundles Dear Ms. Connelly: In your letter dated March 12, 2026, on behalf of your client, Strebesana Resources LLC, you requested a country of origin ruling on optical imaging fiber bundles. There are two items at issue with this request, which are described as optical imaging fiber bundles for use in a laser endoscopy system. The model numbers are 5665 and 5029. We note that for both model numbers, the manufacturing process begins with the creation of a preform, and the steps for this are identical for both items. In Japan, individual quartz rods are gathered in the required number to create the preform where each rod correlates to a pixel fiber. This preform is fused together under heat and then drawn to the necessary diameter before a protective coating is added. The optical fibers are then cut to length and polished. The finished optical fiber image bundle is sent to China where the coating is stripped on one end and the end is cleaned. Then, components of either Chinese or US origin are added, including a tip lens assembly, bundle lens, and lens tube. The optical imaging fiber bundles are then checked for image quality and packaged for shipment. 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). In the instant case, the glass preforms are manufactured with specific attributes and qualities that are predetermined by the materials used to manufacture the preform. It is the opinion of this office that the preforms manufactured in Japan impart the character of the finished bundles. Further, the final assembly process taking place in China, including the stripping, cleaning, and the addition of the tip lens assembly, lens bundle, and lens tube, does not substantially transform the optical fibers into new and different articles of commerce. Accordingly, based on the facts presented, the origin of the fiber optic cables, will be Japan. 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 Gary Chaffee at gary.chaffee@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division