The country of origin of two battery chargers

N353830
October 1, 2025
OT:RR:NC:N2:212
CATEGORY: Origin Mason Zheng Talway Vit Nam T-2-1-1 and T-2-1-2, Que Vo Industrial Zone (Extension Area), Nam Son Ward Bac Ninh 16000 Vietnam RE: The country of origin of two battery chargers Dear Mr. Zheng: In your letter dated September 16, 2025, you requested a country of origin ruling on two battery chargers. There are two items at issue with this request, which are each described as High Frequency Battery Chargers and individually identified by model numbers HFN10DVD and HFN0216DVD. Both chargers are comprised of a mainboard and control printed circuit board assembly (PCBA) within an enclosure. On the face of the charger is an LCD display and control buttons. The chargers incorporate a standard wall electrical cord as well as charging cables with copper clamps. The products are used to charge various batteries, such as vehicle batteries, with the primary difference being the size and maximum operating current. In your request, you state that the manufacturing process for both battery chargers, models HFN10DVD and HFN0216DVD, are identical. Components from China and Vietnam are shipped to Vietnam where both the mainboard PCBA and the control board PCBA are produced by solder paste printing, reflow soldering and through-hole assembly of various electronic components, onto a bare printed circuit board. Both 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 case is closed by adding the front and rear shell. Voltage withstand testing, functionality testing, and aging testing take place, then labels are then printed and pasted to the battery charger. A visual inspection occurs and the finished product is given a final test and is packaged for export 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 battery chargers, in our view, the assembly of both 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 battery chargers. Thus, the country of origin for the High Frequency Battery Chargers, models HFN10DVD and HFN0216DVD, is Vietnam 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 Designated Official Performing the Duties of the Division Director National Commodity Specialist Division