The tariff classification of battery components from China

N351340 August 5, 2025 CLA-2-85:OT:RR:NC:N1:103 CATEGORY: Classification TARIFF NO.: 8507.90.8000; 9903.01.24; 9903.01.25; 9903.88.01 Julie Yan Pan American Automotive Parts Trading LLC 602 Brents Road Lewisburg, TN 37091 RE: The tariff classification of battery components from China Dear Ms. Yan: In your letter dated July 15, 2025, you requested a tariff classification ruling. The first item under consideration is referred to as a battery shell, part number M32S1, and is described as a structural case for a lithium-ion prismatic battery cell. The shell is shaped like a rectangular cuboid with an open top and open bottom. The covers for the top and bottom of the battery cell will be installed during the manufacturing process and are not part of this request. The shell is extruded from aluminum alloy and measures approximately 126 millimeters in width, 256 millimeters in height, 32 millimeters in thickness, and weighs 130 grams. A single safety vent is included in the side panel of the shell. The second item under consideration is referred to as a battery shell, part number M32S2. It is identical to part number M32S1 in function, material composition, construction, and dimensions. The only difference is that it will be formed from an aluminum coil instead of using an extrusion process. The third item under consideration is referred to as a battery shell without a safety vent, part number 71173C, and is in the form of a rectangular cuboid with an open top. It is made from aluminum alloy and measures approximately 187 millimeters in width, 207 millimeters in height, 72 millimeters in thickness, and weighs 255 grams. You state that the shell will be used during the production of a lithium-ion prismatic battery cell. The fourth item under consideration is referred to as a can lid, part number 71173L, and is described as the cover assembly for the battery shell (part number 71173C) described above. The assembly consists of an aluminum top plate, a lower plastic plate, a burst disc, an anode tab, a cathode tab, O-rings, and terminals. The applicable subheading for the battery shell, part numbers M32S1, M32S2, and 71173C, and the can lid, part number 71173l, will be 8507.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Parts: Other.” The general rate of duty will be 3.4 percent ad valorem. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 8507.90.8000, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8507.90.8000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8507.90.8000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8507.90.8000, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively. The merchandise in question may be subject to antidumping duties and countervailing duties (AD/CVD). Written decisions regarding the scope of AD/CVD orders are issued by the Enforcement and Compliance office in the International Trade Administration of the Department of Commerce and are separate from tariff classification and origin rulings issued by CBP. You can contact them at https://trade.gov/enforcement/ (click on “Contact Us”). For your information, you can view a list of current AD/CVD cases at the United States International Trade Commission website at https://www.usitc.gov/trade_remedy/documents/orders.xls, and you can search AD/CVD deposit and liquidation messages using CBP’s AD/CVD Search tool at https://aceservices.cbp.dhs.gov/adcvdweb. The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. 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 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division