The country of origin of two models of battery chargers

N352306 August 22, 2025 OT:RR:NC:N2:212 CATEGORY: Origin David Forgue Barnes, Richardson & Colburn, LLP 303 East Wacker Drive, Suite 305 Chicago, IL 60601 RE: The country of origin of two models of battery chargers Dear Mr. Forgue: In your letter dated August 12, 2025, you requested a country of origin ruling on behalf of your client, CTEK, Inc. The first item under consideration is identified as the CTEK Battery Charger Model NXT 5, which is described as being intended for use with all types of lead-acid 12-volt batteries, i.e. conventional vehicle batteries. The charger consists of a plastic enclosure, having a main printed circuit board assembly (PCBA), electrical cables, and LED indicators. The charger has a built-in automatic temperature sensor and combination of advanced charging modes, allowing it to charge in all types of weather. The NXT 5 also has a special reconditioning function that restores stratified and deeply discharged batteries, unique maintenance charging, and the charging of demanding AGM batteries. The second item under consideration is identified as the CTEK Battery Charger Model NXT 15, which is described as being for use with all types of lead-acid 12-volt batteries, including a dedicated mode for lithium batteries, with compatibility to batteries from 40 Ah to 500 Ah (30 Ah to 450 Ah lithium). The charger consists of a plastic enclosure, having a main printed circuit board assembly (PCBA), electrical cables/clamps, and LED indicators. The charger is fully automatic with integrated safety features including being spark proof construction and reverse-polarity protection. In your letter, you state that the PCBAs for each model under consideration are produced in Malaysia by surface mounting and through-hole insertion soldering of various electronic components, such as resistors, capacitors, transformers, diodes, triodes, fuses and integrated circuits, etc., onto a bare printed circuit board. The PCBAs are also loaded with firmware and tested in Malaysia, prior to being exported to China. In China, the PCBA is assembled with the balance of parts and components that are of Chinese and other origin, which include the plastic covers, electrical cables, connectors, etc. Once assembly is completed, the battery chargers are tested and packaged for export. 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 country of origin of the subject battery chargers, in our view, the assembly of the PCBA in Malaysia by surface mounting and through-hole insertion soldering of various electronic components, such as resistors, capacitors, transformers, diodes, triodes, fuses and integrated circuits, etc., onto a bare printed circuit board results in a substantial transformation of the components to produce PCBAs of Malaysian origin. Furthermore, it is the opinion of this office that the PCBA, which functions to convert the input voltage and control the charging of the attached battery, establishes the character of the electrical charging function. In our view, the assembly processes done in China, which includes inserting, attaching, gluing, etc., are not complex and are considered basic assembly. As a result, we find that the Malaysian origin PCBAs are not substantially transformed in China into different articles of commerce with new names, characters, and uses. Thus, the CTEK Battery Chargers, Model NXT 5 and Model NXT 15 are considered products of Malaysia for origin purposes 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 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