The country of origin of three models of optical amplifiers

N361849 June 16, 2026 OT:RR:NC:N2:209 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of three models of optical amplifiers Dear Ms. Murrin: In your letter dated May 28, 2026, you requested a country of origin ruling on behalf of your client, Accelink Technologies, for three models of optical amplifiers (OA). The items concerned are three models of OA, identified as part numbers RPM-C/L-14.5-09-06-LU-5B, EDFA-MW-VGA-L60-15/25-24-0-0-LC/UPC, and EDFA-MW-A16-963/1220-5/38-L. These OA devices are used in fiber-optic communication systems to boost the strength of an optical signal without converting it into an electrical signal. This allows data to travel longer distances with minimal loss. In the OA, the printed circuit board assembly (PCBA) powers the pump lasers, which generate high-energy pump light. That pump light is then combined with the incoming signal light using a wavelength-division multiplexer (WDM). The combined light travels through the optical fiber, where the pump energy transfers to and strengthens the signal, amplifying it so it can continue across the network with significantly less attenuation. The manufacturing process for the OA occurs in Malaysia, using components, including the Pump Laser (Japan), Photodetector (China), PCBA (Malaysia), WDM (China), passive optical splitter (China), optical component (China), and Collimator (China). The first step is the PCBA assembly, which is as follows: 1. The printed circuit board will undergo solder paste printing. 2. The board will undergo an initial solder paste inspection (SPI). 3. The board’s solder side will be surface-mounted by means of a pick-and-place machine that populates the solder side of the board with its dedicated PCBA components. 4. The solder side will undergo solder reflow to permanently adhere the components to the board. 5. The PCBA will undergo automated optical inspection (AOI). 6. The PCBA will undergo an automated 3D x-ray inspection. 7. The PCBA will undergo another round of SMT subprocess, repeating all previous steps. 8. The PCBA will then undergo conformal coating to protect the PCBA and its components from moisture, dust, or other forms of damage. The coating is then dried and baked. 9. The PCBA will undergo a manual visual inspection via microscope. Butterfly-shaped pump forming machines and pin dedicated automatic forming machines are then used to shape the pins to the correct height and length. Electrical installation is performed using equipment such as a computer, ion fan, exhaust fan, electric screwdriver, forceps, dispensing machine, glue application fixture and 3M fine insulating tape. The process includes installing the cover plate onto the mechanical housing, as well as pump installation while maintaining proper welding iron temperature controls. During soldering, all welding holes are filled with solder, and the solder surface must exhibit strong adhesion to the pins. The resulting solder joints must be uniform, complete, and exhibit a smooth, shiny finish, with no evidence of short circuits, poor soldering, or missing solder. Next, passive optical components for each module’s serial number are placed into a tray in the correct order. Fiber coils are arranged carefully to prevent them from contacting sharp components that could cause damage. Finally, the manufacturer uses specialized optical test equipment, to verify that each module meets performance specifications. The finished OA is inspected and packaged for export into 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). Based on the facts presented, it is the opinion of this office that the PCBA, which is the component that houses the electronics that control and coordinate the amplifier’s core optical functions, is the fundamental functional component for the functional OA. The PCBA contains microcontrollers, power management circuitry, signal processing elements, and firmware interfaces responsible for regulating pump laser output, monitoring optical conditions, managing safety interlocks, and ensuring stable Raman gain. The PCBA also undergoes the most complex and transformative manufacturing operations within the OA production process. In Malaysia, its assembly requires SMT component placement, soldering, diagnostics, testing, firmware installation, and calibration, steps that provide the device’s intelligence, operational logic, and final functionality. In contrast, the remaining components incorporated into the OA in Malaysia, such as optical splitters or WDMs, are largely passive and do not define the device’s essential character on their own. In view of these facts, the country of origin for all three models of optical amplifiers, identified as part numbers RPM-C/L-14.5-09-06-LU-5B, EDFA-MW-VGA-L60-15/25-24-0-0-LC/UPC, and EDFA-MW-A16-963/1220-5/38-L is Malaysia for the purpose of applying current trade remedies and additional duties. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division