N355544

N355544 November 19, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Crystal Yang 16/F, Building 1, Nanshan iPark Chongwen, No.3370 Liuxian Avenue, Xili Nanshan, Shenzhen China RE: The country of origin of fiber optic cassettes Dear Ms. Yang: In your letter dated October 31, 2025, you requested a country of origin ruling. There are five items at issue with this request, which are described as Multi-Fiber Push On (MPO) Cassettes and identified by the below five part numbers: FHD-1MTP12LCDOM4A FHD-1MTP12LCDSMFA FHD-2MTP12LCDOM4A FHD-2MTP12LCDSMFA FHD-1MTP12LCDOM4AF The subject articles consist of a fiber optic cable jumper assembly with connectors affixed at each end and enclosed within a tray, referred to as the cassette. The primary difference between the models is the type of fiber optic connectors at the ends. The subject assemblies function identically and are used to provide fiber optic network connection within a commercial or private installation. In your request, you state that the manufacturing process for all five models is identical and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. The fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length, colored and jacketed with yarn. The end of the cable is then stripped and the specific connector is assembled and crimped onto the end of the core. This creates the jumper assembly. The jumper assembly is then wound within the lower tray of the cassette prior to being fully enclosed within the cassette case. The final MPO Cassette is then packaged for shipment to the U.S. 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). Regarding the origin of the subject cassettes, it is the opinion of this office that the jumper assemblies, which incorporate U.S. origin optical fibers, impart the character of the finished device. Further, the assembly process performed to manufacture the finished product in China is not significantly complex to substantially transform the optical jumper assemblies. As the jumper assemblies would be considered U.S. origin, the finished MPO Cassettes, referenced by the below part numbers, would also be considered U.S. origin. FHD-1MTP12LCDOM4A FHD-1MTP12LCDSMFA FHD-2MTP12LCDOM4A FHD-2MTP12LCDSMFA FHD-1MTP12LCDOM4AF 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 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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). Regarding the origin of the subject cassettes, it is the opinion of this office that the jumper assemblies, which incorporate U.S. origin optical fibers, impart the character of the finished device. Further, the assembly process performed to manufacture the finished product in China is not significantly complex to substantially transform the optical jumper assemblies. As the jumper assemblies would be considered U.S. origin, the finished MPO Cassettes, referenced by the below part numbers, would also be considered U.S. origin. FHD-1MTP12LCDOM4A FHD-1MTP12LCDSMFA FHD-2MTP12LCDOM4A FHD-2MTP12LCDSMFA FHD-1MTP12LCDOM4AF 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 comple