N360882

N360882May 15, 2026CLA-2-39:OT:RR:NC:N4:415 CATEGORY: Classification; Country of Origin TARIFF NO.: 3926.90.9989; 9013.90.8000 Alexis KwakClearfield, Inc.7050 Winnetka Avenue North, Suite 100Brooklyn Park, MN 55428RE: The classification and country of origin of a fiber optic enclosure and its plastic components.Dear Ms. Kwak:In your letter dated April 21, 2026 , you requested a tariff classification and country of origin ruling.Images were provided in lieu of samples.The primary product under consideration is described as the “OC 250 Dome Splice Closure Kit,” part number024985. It is designed to store and secure spliced fiber optic cables and features multiple splice trays housedin a weatherproof dome cover that is clamped and sealed to a base endplate. We agree this enclosure issimilar to the one described in New York ruling letter N331709, dated April 19, 2023, and we will classify itin the same manner under heading 9013.In your request, you indicated your supplier wanted to classify this complete kit under subheading8517.62.0090, Harmonized Tariff Schedule of the United States (“HTSUS”). We note that there are noactive electrical components that facilitate the transmission or reception of data. This tariff number coversactive data transmission apparatus that receives, converts, and transmits a data signal. A passive,nonelectrical article such as the subject closure kit would not be classified within heading 8517. As such, itwould not be appropriate to classify this product within subheading 8517.62.0090, HTSUS.Additionally, you requested the classification of the following components if imported separately: 250 benchadapter, hinge adapter (red), bench clamp fixture, hinge adapter (orange), dome cover, and dome clampassembly. You indicate they are all made of molded plastic, and we would agree with your proposedclassification within heading 3926. The applicable subheading for the “OC 250 Dome Splice Closure Kit,” part number 024985, will be9013.90.8000, HTSUS, which provides for “[l]asers, other than laser diodes; other optical appliances andinstruments, not specified or included elsewhere in this chapter: [p]arts and accessories: [o]ther: [o]ther.” The column one, general rate of duty is 4.5 percent ad valorem.As the molded plastic components would be considered articles of plastic, and as they are not morespecifically provided for elsewhere, the applicable subheading will be 3926.90.9989, HTSUS, whichprovides for “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther:[o]ther: [o]ther.” The column one, general rate of duty is 5.3 percent ad valorem.The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenienceand are subject to change. The text of the most recent HTSUS and the accompanying duty rates are providedat https://hts.usitc.gov/.You also asked for clarification on the country of origin of these products. In your submission, you state thatall these components are molded into their final form in China and then in Thailand they undergo a simpleassembly process to create the finished splice closure kit. Once completed in Thailand, they are then packagefor export to the United States.When determining the country of origin, the substantial transformation analysis is applicable. , e.g.,SeeHeadquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether asubstantial 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. SeeTexas Instruments Inc., 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. v. United States , 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).SeeNational Hand Tool Corp. v. United StatesIn order to determine whether a substantial transformation occurs when components are assembled intocompleted products, all factors such as the components used to create the product and manufacturingprocesses that these components undergo are considered in order to determine whether a product with a newname, character, and use has been produced. No one factor is decisive, and assembly/manufacturingoperations that are minimal will generally not result in a substantial transformation.From the information provided, we agree that the molded plastic components are not substantiallytransformed to become new articles having a new name, character, or use after the simple assemblyperformed in Thailand. Accordingly, the country of origin for this fiber optic enclosure and its plasticcomponents will remain China.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please refer to the frequently updated CargoSystems Messaging Service (“CSMS”) messages athttps://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions onthe Trade Remedy/IEEPA page athttps://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 accurateand complete in every material respect. In the event that the facts are modified in any way, or if the goods donot conform to these facts at time of importation, you should bring this to the attention of CBP and submit arequest for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material factsdescribed 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 CBP Regulations (19 CFR 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, contactNational Import Specialist Kristopher Burton at kristopher.burton@cbp.dhs.gov. Sincerely, (for)James P. ForkanDirectorNational Commodity Specialist Division

is applicable. , e.g.,SeeHeadquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether asubstantial 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. SeeTexas Instruments Inc., 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. v. United States , 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).SeeNational Hand Tool Corp. v. United StatesIn order to determine whether a substantial transformation occurs when components are assembled intocompleted products, all factors such as the components used to create the product and manufacturingprocesses that these components undergo are considered in order to determine whether a product with a newname, character, and use has been produced. No one factor is decisive, and assembly/manufacturingoperations that are minimal will generally not result in a substantial transformation.From the information provided, we agree that the molded plastic components are not substantiallytransformed to become new articles having a new name, character, or use after the simple assemblyperformed in Thailand. Accordingly, the country of origin for this fiber optic enclosure and its plasticcomponents will remain China.This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or othercharges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and otherduties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to theclassification stated above, the merchandise covered by this ruling may also need to be reported with eitherthe Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisionscovering exceptions to such tariffs.For further information to assist with the importation process, please re