The country of origin of a lead-acid jump starter

N356670
December 23, 2025
OT:RR:NC:N1:103
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 lead-acid jump starter Dear Ms. Chen: In your letter dated December 3, 2025, you requested a country of origin ruling. The merchandise under consideration, model number DL800A/GM011, is a lead-acid jump starter designed to start cars, light trucks, boats, lawn and garden equipment, etc., delivering up to 250 cold cranking amps and 800 peak amps. It can also function as a power bank for charging electronic devices. The jump starter consists of a durable case with a high-performance lead-acid battery, capacity indicators, an audible alarm, a 12 V cigarette lighter socket, a USB-A output port, and an LED work light. The subject jump starter is assembled in Vietnam using components sourced from China and Vietnam. The main Chinese components include a power supply, a printed circuit board assembly, and miscellaneous electrical parts, including a power cord, wires, and switches. The Vietnamese components include outer plastic shells, terminal blocks, wires, and a sealed lead-acid battery that accounts for most of the product’s value. The assembly process consists of mounting the sealed lead-acid battery, a front panel, a cigarette lighter socket, a lamp assembly, and the printed circuit board assembly inside the front shell and securing them using self-tapping screws. Next, a worker completes the electrical wiring, connects the alligator clamps, installs the rear shell, tests all functions of the unit, and packages the jump starter with a power supply. 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).

CBP has held that whether an assembly process is sufficiently complex to rise to the level of a substantial transformation is determined upon consideration of all the operations that occur within that country. Based on the information in your submission, the final assembly operations that occur in Vietnam are not complex. Turning to the components of the jump starter, we find that the primary component is the Vietnamese sealed lead-acid battery, which also accounts for most of the device’s value. The lead-acid battery performs the principal function of maintaining an independent source of electricity in order to deliver significant current to start cars, light trucks, ATVs, boats, lawn, garden equipment, and other 12V devices. Therefore, in view of these facts, and based on the totality of the circumstances, the country of origin of the subject lead-acid jump starter, model number DL800A/GM011, is Vietnam. 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 [email protected].
Sincerely,
(for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division