The country of origin of a lithium hexafluorophosphate solution

N358415
February 25, 2026
OT:RR:NC:N3:139
CATEGORY: Origin Chulwan Park Daewon Customs Consulting Service 131-1 Dosan-ro Nam-gu , Ulsan 44728 Republic of Korea RE: The country of origin of a lithium hexafluorophosphate solution Dear Mr. Park: In your letter made on behalf of your client Foosung Company Limited dated February 2, 2026, you requested a country of origin ruling on lithium hexafluorophosphate in an ester solvent. In your submission you state that this item will be a battery grade liquid electrolyte solution for use in lithium ion batteries. Lithium fluoride is synthesized by Foosung in Korea. Phosphorus pentafluoride is also generated by them from feedstocks sourced from Korea, and other countries. You state the phosphorus pentafluoride is then reacted with a purified ester solvent from Country A. After this, the lithium fluoride is fed into the reactor vessel, and various impurities are removed. After purification, the solution is standardized to battery-grade specifications required for lithium-ion battery electrolyte manufacturing. Each production lot undergoes quality testing, and a Certificate of Analysis is issued to confirm conformity with established specifications. The finished product is then filled, sealed, and prepared for commercial distribution. 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). It is well established that the use of lithium hexafluorophosphate in combination with carbonate esters makes an effective electrolyte solution for the use in lithium ion batteries1 something neither product could accomplish independent of the other. Although no chemical reaction has occurred as a result of this mixing, a product has emerged with a significant new use indicating that a substantial transformation has occurred.

The country of origin of the lithium hexafluorophosphate solution for purposes of Section 301 remedies will be Korea, and Section 301 duties will not apply. 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 John Bobel at [email protected]. 1Jow, T. Richard; Borodin, Oleg; Ue, Makoto; Xu, Kang (2014). Electrolytes for Lithium and Lithium-Ion Batteries. Springer: New York.
Sincerely,
(for) James Forkan Designated Official Performing the Duties of the Division Director National Commodity Specialist Division