The country of origin of a power bank

N352355 September 3, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Debby Anderson Odyssey International Services 305 Bridgepoint Drive, Suite 150 South St. Paul, MN 55075 RE: The country of origin of a power bank Dear Ms. Anderson: In your letter dated August 13, 2025, you requested a country of origin ruling on behalf of your client, Chug Inc. The merchandise under consideration is identified as the Deal Worthy 4,000 mAh power bank, model number PB41, and is described as a portable battery for charging electronic devices. It consists of two lithium-ion battery cells enclosed in a plastic case with power indicator lights, a USB-A output connector, and a micro-USB input connector. The power bank has a nominal capacity of 4,000 mAh and a nominal energy of 14.8 Wh. The subject power bank will be assembled in China from components sourced from Vietnam and China. The Vietnamese components include a printed circuit board assembly (with a USB-A and a micro-USB connector), a light guide, a light shield, a plastic button, and an injection molded case. The Chinese components are identified as two cylindrical lithium-ion battery cells and a charging cable. Final assembly starts with combining the printed circuit board assembly and battery cells. This involves inspecting each component, soldering wires to the printed circuit board assembly, welding a nickel strip to two battery cells, and then welding the wires from the printed circuit board assembly to the battery cells. This assembly is placed inside a bottom case with a pre-installed button, light guide, and light shield. Lastly, the top case is installed, and the device is tested, inspected, and packaged with the charging cable. 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). U.S. Customs and Border Protection has previously held that the assembly of battery cells into a power bank 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 cell is to store and provide power, and the function of the battery cell 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 subject power bank, model number PB41, is China. 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) Denise Faingar Acting Director National Commodity Specialist Division