The country of origin of the Electric Vehicle Battery Charger

N349313 June 6, 2025 OT:RR:NC:N2:220 CATEGORY: Origin Dowon Choi Seju Customs Firm Rm 602 6 Eonju-ro 141-gil Gangnam-gu Seoul 06050 Republic Of Korea RE: The country of origin of the Electric Vehicle Battery Charger Dear Mr. Choi: In your letter dated May 22, 2025, you requested a country of origin ruling on behalf of your client, SK Signet. The merchandise under consideration is identified as the Electric Vehicle Battery Charger (Charger), Model AFCK20-S00041, which is described as an enclosure containing electrical distribution apparatus, a front facing touchscreen control interface, dual charging controllers, an AC/DC converter, a DC/DC converter, and various control and payment/communication circuitry. The 32” LCD user touchscreen incorporates a payment system and can be configured for advertisement and/or video as well as system status. On the top of the unit is a banner LED display that is used to notify users of availability and status. Extending from each side of the enclosure are two electrical cables that are intended to attach to an electric vehicle for periodic charging. In your submission, you state that the inverter, which you identify as the Power Block, is manufactured in China. In Korea, eight printed circuit board assemblies (PCBAs), identified as the Main Control Board, the IMD Board, the Power ADC Board, the LED Sub Board, and the DP Reset Board, are manufactured by soldering individual components, such as resistors, capacitors, integrated circuits, transformers, etc. onto bare printed circuit boards through a surface mount and/or through-hole insertion process. Also in Korea, the Korean origin Industrial PC is integrated, the human machine interface, numerous circuit breakers, electrical connection apparatus, and cables, which are said to be manufactured in Korea, are assembled into the enclosure. The Charger is tested and packaged for export to the United States. 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). Regarding the origin of the Charger, the assembly of the PCBAs by soldering the individual components of various origins onto bare printed circuit boards in Korea results in a substantial transformation of those components to produce five PCBAs of Korean origin. While the Power Module, which is produced in China, is an important component of the Charger, in our view, the Korean origin electrical conversion, control, and distribution, as well as the assembly operation occurring in Korea, establish the bulk of the functionality of the Charger. As a result, the Electric Vehicle Battery Charger (Charger), Model AFCK20-S00041, is considered a product of Korea at the time of importation into the United States. 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 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, (for) Steven A. Mack Director National Commodity Specialist Division