The country of origin of Lithium Iron Phosphate Cathode Active Material

N358366 February 23, 2026 OT:RR:NC:N3:136 CATEGORY: Origin Peter Paik Kim & Chang 39, Sajik-ro 8-gil, Jongno-gu Seoul 03170 Korea, South RE: The country of origin of Lithium Iron Phosphate Cathode Active Material Dear Mr. Paik: In your letter dated January 30, 2026, on behalf of your client, POSCO Future M, Co., Ltd., you requested a country of origin ruling on Lithium Iron Phosphate Cathode Active Material (LFP CAM). In your submission, the subject product is described as a certain cathode active material made from lithium, iron, and phosphate (LFP CAM). This material is intended for use in secondary (rechargeable) lithium-ion batteries manufactured for energy storage systems (ESSs) in the Unites States. The LFP CAM is engineered to provide a stable and cost-efficient cathode active material that meets the rapidly growing demand for storage capacity in ESSs. You describe a scenario where the subject LFP CAM will be produced in the Republic of Korea (Korea) using foreign sourced precursor materials. The LFP CAM will be manufactured in Korea using your client’s proprietary technologies and production processes, starting from a mixture of precursor materials consisting of: Main Precursor: FePO4, CAS # 10045-86-0 Lithium Source: Li2CO3, CAS # 554-13-2 Carbon Source: C6Hl2O6, CAS # 50-99-7 Dispersing Agent: PEG, CAS # 25322-68-3 The manufacturing process is described as follows: During heat treatment and deagglomeration processes in Korea, the LFP precursor mixture undergoes c hemical reactions that form a new chemical substance - lithium iron phosphate (LFP), with the chemical formula LiFePO4. The carbon source contained in the LFP Precursor Mixture forms a uniform, continuous layer of amorphous carbon around the LFP particle surfaces. These chemical and physical transformations alter the physical and electrochemical properties of the LFP Precursor Mixture and enable a new functionality . The resulting material becomes suitable for use as LFP CAM in lithium-ion batteries. The finished LFP CAM will be exported from Korea 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 country of origin of the LFP CAM, it is our view that the foreign sourced mixture of precursor materials undergoes a substantial transformation during the manufacturing processing in Korea. The described chemical reactions that form a new chemical substance result in a substantial transformation of the LFP precursor mixture. Therefore, it is the opinion of this office that the country of origin of the LFP CAM is 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 Nuccio Fera at nuccio.fera@cbp.dhs.gov. Sincerely, (for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division