The country of origin of lead-acid automotive batteries

N362506 July 15, 2026 OT:RR:NC:N1:103 CATEGORY: Origin Horacio Chapa Uni-Trade Brokers LC 130 Flecha Ln. Laredo, TX 78045 RE: The country of origin of lead-acid automotive batteries Dear Mr. Chapa: In your letter dated June 23, 2026, you requested a country of origin determination for marking purposes on behalf of your client, Recicladora Industrial de Acumuladores S.A. de C.V. The merchandise under consideration is identified as lead-acid automotive batteries designed for starting piston engines. The batteries will be imported under various part numbers depending on group size, terminal type, and other specifications. Two representative part numbers were provided: part number 1030049 is a group size 35, 12 VDC battery rated at 550 CCA and weighing 17.3 kilograms; part number 1023525 is a group size 65, 12 VDC battery rated at 850 CCA and weighing 22 kilograms. The lead-acid batteries will be manufactured from waste and scrap batteries sourced from the United States. These used batteries are exported to Mexico, where they are crushed and separated into lead-bearing components, polypropylene plastic, and electrolyte. The resulting materials are further processed into raw materials, which will then be used to create new batteries. In Mexico, the recovered plastic is chemically washed, dried, and ground into pellets. These pellets are then used in a formative manufacturing process, where they are molded into new battery cases and covers. Lead is recovered using a pyrometallurgical process that blends the materials with fluxes and reducing agents. This blend is smelted in a rotary furnace, further processed in a refining kettle, and cast into ingots, which are then used to produce lead plates. The lead plates, plastic cases, plastic covers, and other components are assembled to produce new lead-acid batteries. These components are sourced from Spain, Thailand, the United States, or domestically within Mexico. Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940). Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or growth of any article of foreign origin entering the United States. Further work or material added to an article in another country must effect a substantial transformation in order to render such other country the “country of origin” within the meaning of the marking laws and regulations. Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining the country of origin of a good for marking purposes, with the exception of textile and apparel goods which are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11. Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in which: (1) The good is wholly obtained or produced; (2) The good is produced exclusively from domestic materials; or (3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable requirements of these rules are satisfied. The lead-acid batteries are neither “wholly obtained or produced” nor “produced exclusively from domestic materials.” Therefore, paragraphs (a)(1) and (a)(2) cannot be used to determine its country of origin, and we need to apply paragraph (a)(3). Under 19 CFR 102.11(a)(3), any foreign materials of the lead-acid batteries must satisfy the tariff shift requirements of 19 CFR 102.20. “Foreign material” is defined in 19 CFR 102.1(e) as “a material whose country of origin as determined under these rules is not the same country as the country in which the good is produced.” The subject lead-acid automotive batteries are classified under subheading 8507.10.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Lead-acid storage batteries, of a kind used for starting piston engines: 12 V batteries: Exceeding 6 kg in weight.” The tariff shift requirement in section 102.20 for a good of subheading 8507.10, HTSUS, requires “a change to subheading 8507.10 through 8507.80 from any other subheading, including another subheading within that group, except for a change to subheading 8507.80 from subheading 8507.50 or 8507.60.” The foreign materials used during production are classified outside of subheading 8507.10, HTSUS. Since all the foreign components satisfy the tariff shift rules set forth in 19 CFR 102.20, the country of origin of the lead-acid batteries, for marking purposes, is Mexico. In your request, you suggest that 19 CFR 102.11(b) should be used to determine the country of origin for marking purposes. However, as noted above the rules set forth in 19 CFR 102.11 are to be applied in sequential order, and the origin can be determined using 19 CFR 102.11(a). 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) James P. Forkan Director National Commodity Specialist Division