The tariff classification and country of origin of a power bank

N351893 August 22, 2025 CLA-2-85:OT:RR:NC:N1:103 CATEGORY: Classification; Origin TARIFF NO.: 8507.60.0020; 9903.01.24; 9903.01.25; 9903.88.15 Deborah Stern Sandler, Travis & Rosenberg, P.A. 5835 Waterford District Drive, Suite 200 Miami, FL 33126 RE: The tariff classification and country of origin of a power bank Dear Ms. Stern: In your letter dated July 31, 2025, you requested a tariff classification and country of origin determination ruling on behalf of your client, Belkin International Ltd. The merchandise under consideration is referred to as the Belkin Magnetic Power Bank with Qi2 5K and is described as a rechargeable lithium-ion power bank with a single USB-C input/output port and a 5,000 mAh capacity. In addition to wired charging, the subject power bank can also wirelessly charge devices using the Qi2 standard up to a 15-watt charging rate. The device also has built-in magnets to help it align with Apple personal electronic devices such as iPhones and Airpods. In your submission, you suggest the subject power bank is classifiable in heading 8504, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof.” We disagree. The purpose of the product is to store and supply electricity. And while there may be some components within the power bank that perform functions covered by heading 8504, they are ancillary components that contribute to the power bank’s function of storing and supplying energy. As such, the applicable subheading for the subject power bank will be 8507.60.0020, HTSUS, which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Lithium-ion batteries: 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 8507.60.0020, 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 of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 8507.60.0020, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8507.60.0020, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8507.60.0020, 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 subject power bank is assembled in Vietnam using Chinese and Vietnamese components. The Chinese components include battery cells, magnets, upper and lower shell housings, a charging coil, and a USB-C charging cord. The sole Vietnamese component is a printed circuit board assembly that will function as the battery management system and facilitate wireless charging. In Vietnam, the charging coil and magnet are soldered to the printed circuit board assembly, which is then connected and welded to the battery cells. Both components are placed inside the lower shell housing along with a button and light guide. Afterwards, an upper shell is secured to the lower assembly using screws. The finished power bank goes through a series of tests and inspections before it is packaged together with the charging cord in retail packaging. 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). Based on the manufacturing scenario presented, the assembly operations that occur in Vietnam do not result in a substantial transformation. There is no change in the name, use, or character of the battery cells after the assembly process occurs. U.S. Customs and Border Protection has previously held that the assembly of battery cells into battery packs does not result in a substantial transformation of the battery cells because the essential character of the cells does not change simply by being placed together in a plastic housing. See HQ ruling 563045, dated August 9, 2004, and HQ ruling 734393, dated March 20, 1992. Here, the function of the battery cells is to store and provide power, and the function of the battery cells in the finished power bank is likewise to store and provide power. In view of these facts, and based on the totality of the circumstances, the country of origin of the Belkin Magnetic Power Bank will be China. 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