The country of origin of a lithium-ion jump starter

N353086 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 lithium-ion jump starter Dear Ms. Chen: In your letter dated August 29, 2025, you requested a country of origin ruling. The merchandise under consideration is a portable lithium-ion jump starter, part number GL056WA, with a nominal capacity of 12,000 mAh. The jump starter is rated for 400 cold cranking amps and is capable of starting vehicles with a 12 V battery. It consists of a lithium-ion battery pack enclosed in a plastic case with a 2.5 millimeter 12 VDC output port, a USB-A output port, a USB-C output port, a work light, and an LCD screen. The device can also be used as a wireless portable charger. The jump starter is assembled in Vietnam using components sourced from China and Vietnam. The Vietnamese components include a lower plastic case, a plastic cover, and a lithium-ion battery pack. The Chinese components include a power supply, an LED backlight, a wireless charging coil, an LCD display, printed circuit board assemblies, and alligator booster clamps. Final assembly begins with assembling the lower portion of the jump starter. This process involves placing the battery pack and the main printed circuit board assembly inside a lower case, securing the components to the case using screws, and connecting the battery pack to the circuit board assembly. Afterwards, a lamp and its circuit board are set in place and connected to the main printed circuit board assembly. At a separate station, a worker prepares the upper cover, which entails attaching anti-slip pads, gluing a wireless charging coil inside the cover, and securing an LCD display board using screws. Once completed, the components in the upper cover are connected to the main printed circuit board assembly before the cover is secured in place. The device is tested and packaged with a power supply, protective carry case, and booster clamps. 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). U.S. Customs and Border Protection (CBP) 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 identity of the cells does not change simply by being placed together in a plastic housing. See Headquarters Ruling Letters 563045, dated August 9, 2004, and 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 jump starter 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 jump starter, part number GL056WA, 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