The country of origin of a jump starter.

N353023 September 25, 2025 OT:RR:NC:N1:103 CATEGORY: Origin Chen Chen Talway Vietnam Company Limited T-2-1-1 and T-2-1-2, Que Vo Industrial Zone (Extension Area), Nam Son Ward, Bac Ninh 16000 Vietnam RE: The country of origin of a jump starter. Dear Ms. Chen: In your letter dated August 28, 2025, you requested a country of origin ruling. The merchandise under consideration is a portable lead acid jump starter, model number DL1000A, with a built-in air compressor and LED work light. Rated for 400 cold cranking amps, the device is used as a portable battery pack for starting cars, light trucks, boats, lawn and garden equipment, etc. It can also be used as a portable power supply and has a 12 V cigarette lighter socket, a USB-A port, and a USB-C port. The subject jump starter is assembled in Vietnam using components sourced from China and Vietnam. The Chinese components include an electric motor, a power supply, printed circuit board assemblies, and miscellaneous electrical parts including a power cord, wires, and switches. The Vietnamese components include a sealed lead acid battery, an air pump, a front shell, and a rear shell. The assembly process begins in Vietnam with assembling the air compressor unit. This involves attaching an electric motor to a bracket, aligning the gears on the motor assembly to a connection rod, connecting an air hose, and testing the subassembly. Afterwards, the sealed lead acid battery, printed circuit board assembly, cigarette lighter socket, light cover, air compressor subassembly, switches, and meters are fixed inside the plastic front shell. The operational steps are described as placing the components inside compartments within the shell structure and securing them to pre-drilled holes using screws. Next, a worker completes the wiring, connects the alligator clamps, installs the rear shell, tests all functions of the unit, and packages the jump starter with a power supply 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). Here, the main component of the subject jump starter is the Vietnamese sealed lead acid battery, which also accounts for the majority of the value of the finished device. The lead acid battery provides the principal function of the device by maintaining an independent source of electricity which can also be used to power one of the secondary devices (i.e., LED light and air compressor). Further, based on the manufacturing scenario presented, the final assembly operations that occur in Vietnam are not exceedingly complex. Therefore, in view of these facts, and based on the totality of the circumstances, the country of origin of the subject jump starter, model number DL1000A, is Vietnam. 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) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division