The country of origin of a power bank

N360412 April 24, 2026 OT:RR:NC:N1:103 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a power bank Dear Ms. Murrin: In your letter dated April 3, 2026, you requested a country of origin ruling on behalf of your client, Anker Innovations Technology Co., Ltd. The merchandise under consideration is identified as the Anker Zolo Magnetic Power Bank, SKU A1685036, and is described as a portable power bank with a 10,000 mAh capacity and a maximum output of 30 W. It consists of two lithium-ion pouch cells encased in a rectangular enclosure with a built-in USB-C cable, a USB-C port, a wireless charging coil, an integrated stand, a power button, and indicator lights. The subject power bank will be assembled in China. All components are sourced domestically in China, except for the lithium-ion pouch cells, which are sourced from India. The assembly process begins by installing a light guide bar, a key button, a magnet, and EVA foam inside a bottom shell. The battery cells, wireless charging coil, and a thermistor are soldered to a printed circuit board assembly, which is then mounted inside the bottom shell and secured with fasteners. Afterwards, workers attach a USB-C cable, apply thermal paste, secure any loose wires with adhesive or tape, and seal the device by pressing the front shell onto the bottom shell. Throughout the process, various functional tests, charging tests, burn-in tests, and inspections are performed. 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 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 Indian battery cells is to store and provide power, and the function of the battery cells 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 Anker Zolo Magnetic Power Bank, SKU A1685036, is India. 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 P. Forkan Director National Commodity Specialist Division