The country of origin of a power bank

N352014 August 21, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a power bank Dear Ms. Murrin: In your letter dated August 5, 2025, you requested a country of origin ruling on behalf of your client, BioLite Energy. The merchandise under consideration is identified as the BioLite Charge 100 Max and is described as a portable lithium-ion power bank with a nominal capacity of 25,000 mAh. It has a 100 W USB-C PD input/output port, a 100 W USB-C PD output port, a 15 W USB-A output port, a 15 W USB-C output port, and a 15 W wireless charging pad. The device measures approximately 5.5 inches in length, 4.4 inches in width, 1.4 inches in thickness, and weighs 580 grams. Five manufacturing scenarios were presented. The operational steps carried out during final assembly are identical for all five scenarios, differing only in the sourcing of components and the country where final assembly will occur. Final assembly entails mounting eight battery cells in a plastic housing. The cells are welded to a printed circuit board assembly (PCBA) that functions as the battery management system (BMS) for the power bank and contains a power button and indicator LEDs. This subassembly is combined with the main PCBA, which is responsible for charging and discharging, DC-DC voltage conversion, monitoring battery health, and interfacing with the USB connectors. Afterwards, an upper shell is installed, and the power bank is tested, which involves running a charge and discharge cycle and verifying the charging ports are operational. In the first scenario, final assembly will take place in China, using Malaysian-sourced battery cells, a Chinese-sourced main PCBA, and a Chinese-sourced BMS. In the second scenario, final assembly will take place in China, using Chinese-sourced battery cells, a Malaysian-sourced main PCBA, and a Chinese-sourced BMS. In the third scenario, final assembly will take place in China, using Chinese-sourced battery cells, a Malaysian-sourced main PCBA, and a Malaysian-sourced BMS. In the fourth scenario, final assembly will take place in Malaysia, using Chinese-sourced battery cells, a Malaysian-sourced main PCBA, and a Malaysian-sourced main BMS. In the last scenario, final assembly will take place in China, using Malaysian-sourced battery cells, a Malaysian-sourced main PCBA, and a Malaysian-sourced main BMS. 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 (HQ) 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). Based on the manufacturing scenarios presented, the assembly operations that occur in China or Malaysia 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 banks 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 BioLite Charge 100 Max will be Malaysia in scenarios one and five. The country of origin of the BioLite Charge 100 Max will be China in scenarios two, three, and four. 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 Paul Huang at paul.huang@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division