The country of origin of a prismatic battery cell

N359554 March 26, 2026 OT:RR:NC:N1:103 CATEGORY: Origin Michael Roll Roll & Harris LLP 2121 Avenue of the Stars, Suite 800 Los Angeles, CA 90067 RE: The country of origin of a prismatic battery cell Dear Mr. Roll: In your letter dated March 9, 2026, you requested a country of origin ruling on behalf of your client, Sunwoda Automotive Energy Technology (Thailand) Co., Ltd. The merchandise under consideration is identified as a prismatic lithium polymer battery cell, model number SBP-01-3140. The cell has a nominal voltage of 3.2 VDC, a nominal capacity of 314 Ah, and a nominal energy of 1,005 Wh. It measures approximately 174.3 millimeters in width, 71.5 millimeters in thickness, and 204.3 millimeters in height. The subject battery cell will be manufactured in Thailand using two scenarios. All materials and components are sourced from China, except for the battery cell cover, the battery cell case, and the negative and positive connectors, which may be sourced from China or domestically in Thailand. The process begins with milling and mixing active materials, conductive agents, solvents, and binders into slurries for the anode and cathode electrodes. A sodium carboxymethyl cellulose binder is dissolved in a solvent, which is then mixed with a graphite material to create the anode electrode slurry. The cathode electrode slurry is produced by combining and mixing lithium iron phosphate, polyvinylidene fluoride, N-methyl-2-pyrrolidone, and carbon black. Depending on the electrode, the slurries are coated onto either an aluminum foil (for the cathode) or a copper foil (for the anode). The coated foils are dried in an oven and then fed into a calendaring machine, which uses rollers to press the coated foil to the required thickness. This process also increases the density and binding strength between the active material and foil. Afterwards, the rolls are slit into strips. In the first scenario, both the anode and cathode material rolls are made in China. In the second scenario, the anode material roll is made in Thailand, and the cathode material roll is made in China. In Thailand, the rolls of electrode material and separators are laser cut to shape and then combined using a winding process. During the winding process, the electrode sheets and separators are layered and wound into a jelly roll, which is then pressed into a rectangular structure. Afterwards, tabs are welded to the jelly roll, which is then wrapped with mylar and placed inside an aluminum case. The battery cell is sealed by welding the top cap to the aluminum case. Finally, the cell undergoes an activation process, which involves pre-charging, injecting electrolyte using high-temperature infiltration, and charging. 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). Based upon the facts presented, various discrete material forms, including liquid chemicals, material rolls, and raw materials are sent to Thailand where they are made into a new product. The foreign materials are used in a manufacturing process that transforms the materials into a prismatic battery cell with a new name, character, and use, different from that possessed by the materials prior to the processing. Therefore, it is the opinion of this office that the manufacturing processes performed in Thailand result in a substantial transformation of the foreign components and the country of origin of the prismatic battery cell is Thailand in both scenarios. 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) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division