The country of origin of a battery charging system

N352190 August 22, 2025 OT:RR:NC:N2:212 CATEGORY: Origin Doowon Choi Seju Customs Corporation 602,6, Eonju-ro 141-gil,Gangnam-gu Seoul 06050 South Korea RE: The country of origin of a battery charging system Dear Mr. Choi: In your letter dated August 8, 2025, you requested a country of origin ruling on behalf of your client, SK Signet. The merchandise at issue with this request is described as an Electric Vehicle Battery Charger System, which is comprised of two Dispenser modules (part number ADPK40-S00062) and a Power Cabinet (Part number APCK60-S00006). The two dispenser units are comprised of an enclosure, within which is the electrical control apparatus, a power supply, and a cooling system. On the outside of the enclosure is a Human Machine Interface (HMI) touchscreen, which allows the user to interact with the device in order to make payment and view system status. Finally, the dispenser unit incorporates the vehicle charging cable with a specified connection point. The Power Cabinet is comprised of various power module assemblies, which function as the power conversion components, within a metal cabinet. Additionally, the cabinet contains a control printed circuit board assembly (PCBA) and motor control assembly, along with various relays, filters, terminal blocks, and circuit breakers. When combined into a system, the three components function as a vehicle charging station, allowing for multiple vehicles to be charged at once. The power cabinet supplies the power and performs the primary conversion and inversion process for the power. The dispenser modules are the charging and interface components of the system. We note that the power cabinet can deliver up to 600kW of power. In your request you state that the power modules, which are incorporated into the power cabinet are manufactured in China and imported into Korea. In Korea, seven PCBAs are manufactured via surface mount technology (SMT) that will be incorporated into the dispenser unit. These PCBAs include the main control board, metering and sensing boards, and the HMI user interface board. Further, four PCBAs are manufactured in Korea for use with the power cabinet, which include the main control board and various relay and jumper boards. Further in Korea, the dispenser unit boards are added to the enclosure along with the HMI screen and the cooling unit, various circuit breakers, connection apparatus, and cables. For the power cabinet, in Korea the Chinese power modules are placed within the enclosure and combined with the various PCBAs listed above. Additionally, the relays, circuit breakers, terminal blocks, and motor control assemblies are added. After the three units are complete, they are packaged together for shipment to the United States. 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 system, it is the opinion of this office that the manufacture of the critical control PCBAs, via SMT, creates the elements that impart the character of the finished device. Though the power modules manufactured in China are important components, the PCBAs along with the advanced assembly process establish the intended functionality of the device. As such, the Electric Vehicle Battery Charger System, when imported together, is considered a product of Korea. 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) James Forkan Acting Director National Commodity Specialist Division