The country of origin of a Wheeled Battery Charger

N353082
September 10, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Elieen 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 City, Bac Ninh Province, 16000 Vietnam RE: The country of origin of a Wheeled Battery Charger Dear Ms. Chen: In your letter dated August 29, 2025, you requested a country of origin ruling. The merchandise under consideration is identified as the Wheeled Charger, which is further described as a portable battery charger primarily used to charge vehicle batteries. The subject charger is comprised of a rectifying Printed Circuit Board Assembly (PCBA) as well as a control PCBA within a steel enclosure. Attached to the enclosure are front-mounted, six-foot booster cables with copper clamps, a retractable handle, and two wheels. On the face of the charger is a control panel allowing the user to select the charge level and duration that will be delivered to the vehicle battery. In your letter, it is stated that components from China and Vietnam are shipped to Vietnam, where both the main rectifying PCBA and control PCBA are produced by surface mounting and through-hole insertion of various electronic components, such as resistors, capacitors, transformers, integrated circuits, fuses, etc. onto a bare printed circuit board. These PCBAs are then tested and made ready for final assembly. The PCBAs are installed into the base case, where wires are inserted, cords are added and the cooling fan is installed. The case is installed to unit and wheels are mounted to the case. Functionality testing, charge testing take place, the retractable handle is installed, and a final appearance check and final retail packaging occurs and the competed Wheeled Charger is exported 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 Wheeled Charger, in our view, the assembly of both of the PCBAs in Vietnam by soldering the individual components onto the bare board results in a substantial transformation of the components used to produce the two main PCBAs of Vietnamese origin. Further, these boards impart the essential electrical components of the finished charger. Thus, the Wheeled Charger is considered a product of Vietnam for origin and marking purposes at the time of importation into the United States. 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 Luke LePage at [email protected].
Sincerely,
(for) Denise Faingar Acting Director National Commodity Specialist Division