N342247

N342247 September 20, 2024 OT:RR:NC:N2:209 CATEGORY: Origin Suzanne Kane Akin Gump Strauss Hauer & Feld LLP 2001 K Street, N.W. Washington, DC 20006 RE: The country of origin of optical transceiver modules Dear Ms. Kane: In your letter dated August 22, 2024, you requested a country of origin ruling, on optical transceiver modules, on behalf of your client, Lumentum Operations, LLC The item concerned is referred to as the CDGR4+ optical transceiver. In use, the subject merchandise is plugged into network routers and switches in data centers and used to convert an electrical signal to an optical signal for long-distance, high-speed data transmission. At the receiving end, another transceiver receives the optical signal and converts it back to an electrical signal. The subject merchandise consists of four main components: the main printed circuit board assembly (“Main PCBA”); the power printed circuit board assembly (“Power PCBA”); two transmitter optical subassemblies (“TOSA” or “TX”); and two receiver optical subassemblies (“ROSA” or “RX”). The main PCBA (manufactured within the Philippines): Within the Philippines, the main PCBA is manufactured from components/elements of various counties of origin. The main PCBA is the foundation of the subject merchandise. It consists of a printed circuit board with several hundred components surface-mounted to it. It incorporates over two-thirds of the subject merchandise’s total components. Most importantly the main PCBA contains two digital signal processor chips for signal amplification, detection, regeneration, and recondition. The digital signal processor chips work with the “TOSA” and “ROSA” subassemblies. On the transmitter side, the digital signal processor chips provide the driving signal to the “TOSA” subassemblies. The digital signal processor chips will amplify, detect, regenerate, and recondition the signal before it can be used to drive the TOSA subassemblies. The signal is not readable by the TOSA subassemblies until it is formatted by the digital signal processor chips. On the receiving side, when the optical transceiver receives a signal by the ROSA subassemblies and converts the optical signal to electrical signal, the electrical signal is not readable by the optical transceiver until it undergoes further processing from the digital signal processor chips. The main PCBA also contains an erasable programmable read-only memory chip (“EPROM”) that will be programmed in the Philippines to provide the required instructions to perform the transceiver function. Other significant components that are die bonded to the Main PCBA in the Philippines include capacitors, crystal oscillators, ferrule beads, inductors, connector integrated circuits, microcontrollers, resistors, re-timers, thermistors, and voltage regulators. The Power PCBA (manufactured within the Philippines): The power PCBA controls whether the subject merchandise has power to function. The power PCBA is composed of numerous components surface-mounted to a PCB in the Philippines. The power PCBA provides voltage or current to the TOSA subassemblies’ laser diode units and photonic integrated circuit. The power PCBA attaches to the Main PCBA by board to board connectors. The TOSA subassemblies (manufactured in China) The TOSA subassemblies are responsible for converting the electrical signal into an optical signal and transmitting the signal over the optical fiber strand connected to it. Four laser diode units and four optical bench assemblies sit atop a photonic integrated circuit. Each laser diode unit generates and focuses a light beam and the respective optical bench assembly reflects the light beam into the photonic integrated circuit. The photonic integrated circuit takes electrical signals from the main PCBA to modulate the collected light. Four lights are combined into a single light beam inside the photonic integrated circuit which is then launched into the fiber optics via the isolate focus optics. The light beam then travels to the receptacle connector and out of the optical transceiver. The TOSA subassemblies are manufactured in China and attached to the PCBA in China. The TOSA block, which controls thermal dissipation, and the TOSA cover are attached to the PCBA in the Philippines. The ROSA subassemblies (manufactured in China) The ROSA subassemblies are responsible for receiving the optical signal transmitted by the TOSA subassembly and converting it back to an electrical signal so that the communication equipment can understand it. The ROSA subassemblies each consist of a ROSA block, four photodiodes, two single-layer capacitors, and a transimpedance amplifier. The ROSA subassemblies each receive and split the light to the four photodiodes according to wavelengths. It is the photodiodes that convert the light into an electrical signal which is then amplified by the transimpedance amplifier. The ROSA subassemblies are manufactured in China and attached onto the main PCBA through an alignment process in China. Manufacturing that takes place in the Philippines: Production in the Philippines includes the creation of two separate PCBAs, the Main PCBA and the Power PCBA, via surface mount technology (“SMT”). The PCBAs consist of numerous components/elements from various countries of origin. The SMT process is a multistage process requiring different types of specialized machines. The SMT process for the Main PCBA is as follows: Step 1: The printed circuit board will undergo solder paste printing. Step 2: The board will undergo an initial solder paste inspection (“SPI”). Step 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. Step 4: The solder side will undergo solder reflow to permanently adhere the components to the board. Step 5: The PCBA will undergo automated optical inspection (“AOI”). Step 6: The PCBA will undergo an automated 3D x-ray inspection. Steps 7 – 12: The PCBA will undergo another round of the SMT subprocess, repeating all previous steps. Step 13 – 14: The PCBA will then undergo conformal coating in order to protect the PCBA and its components from moisture, dust, or other forms of damage. The coating is then dried and baked. Step 15: The PCBA will undergo a manual visual inspection via microscope. The manufacturing process for the power PCBA is as follows: The SMT process for the power PCBA largely mirrors the process for the main PCBA in that the process involves all of the above-described steps but does not repeat steps 7 – 12 and does not require coating nor baking. In effect, the SMT of the Power PCBA involves steps 1 – 6 and 15. After the manufacture of the Main PCBA in the Philippines, the Main PCBA is sent to China for the ROSA and TOSA subassemblies to be attached to the Main PCBA. Manufacturing that takes place in China: ROSA subassembly is manufactured within China. It requires 20 minutes of assembly time. The process begins with die-bonding of components (which include photodiodes, capacitors, and transimpedance amplifier) to the main PCBA. Next, the ROSA subassemblies undergo a wire bonding process for less than one minute which allows for the signal to flow across the ROSA components. After wire-bonding, the ROSA block is attached to the main PCBA via a UV curing process and actively aligned in order to provide optical receiving functions once the manufacturing of the subject merchandise is completed. A protective cover is then added to protect the ROSA subassembly via a UV curing process. TOSA subassembly is manufactured within China. It requires approximately 16 minutes of assembly time. The TOSA subassembly’s light sources are first loaded, then power calibrated. The light sources are attached to the main PCBA which ultimately serve as the light sources to the optical signal from the transceiver. These processes are brief and require a low level of worker-skill. Next, the Isolate Focus O

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, Steven A. Mack Director National Commodity Specialist Division