The country of origin of a battery tester

N360603
May 5, 2026
OT:RR:NC:N1:105
CATEGORY: Origin Elieen Chen Talway Vietnam Company Limited Lot F2, Nam Son - Hap Linh Industrial Park Tan Chi Commune, Tien Du District Bac Ninh Province 16000 Vietnan RE: The country of origin of a battery tester Dear Ms. Chen: In your letter dated April 10, 2026, you requested a country of origin ruling on a battery tester. Descriptive literature was provided for our review. The item under consideration is described as a battery tester (model BT103A), which is a handheld electronic device and diagnostic tool designed for testing the load, condition, and starter motor draw of 6V and 12V lead-acid batteries up to 1000 CCA. It provides a complete charging system diagnosis for vehicles such as cars, recreational vehicles (RVs), and motorcycles, features a top-mounted rocker switch, a 0-16VDC meter, and heavy-duty, color-coded clamps. The unit is constructed with a ventilated baked enamel steel case and includes a voltmeter, resistance wire, test gauge, copper wire, and clamp cables. When conducting a battery load test, the user first determines whether the dial pointer is point at zero on the meter scale. The positive (red) clamp of the tester is connected to the positive terminal of the battery, followed by connecting the negative (black) clamp to the negative terminal of the battery. Once both clamps are connected, the user then pushes the spring-loaded switch to the on position and holds the switch for at least 10 seconds. While the switch is in the on position, the user then checks the 6-volt or 12-volt section of the meter scale to identify the voltage level and condition of the battery. The battery tester is produced with components from China and Vietnam. The Chinese-origin components include clamp plates, top and bottom covers (black powder-coated), handles in red and black color, voltmeter (0-16V), rocker-type reset switch, resistance wire, a variety of screws, hex head bolt and washer assembly, and nuts, PVC pure copper singled wires with various OT and locking terminals, PVC copper-clad aluminum cable clips and terminals, black PVC wire, OT terminals and brass tin-plated locking flat female terminals, PVC pellets, and mica sheet. The Vietnam-origin components consist of single copper wire, PVC wires in black and red, 600V black heat shrink tubing, tin-plated brass terminal blocks and disc terminals, locking flat female terminals, packaging materials, labels, and instructions manual.

The manufacturing process, conducted in Vietnam, begins with the mounting of mica sheets onto the resistance wire. This involves clamping the resistance wire to the sheets, followed by securing the red OT terminal wire and red clip wire to the right side of the resistance wire with an M5 nut. Concurrently, a fixed black OT terminal wire with a locking mechanism is secured to the left side of the resistance wire, also using an M5 nut. An inspection then ensures the secure fixation of the resistance wire and terminal connections. Subsequently, the resistance wire and mica sheet assembly are installed into the upper housing’s mounting slots. This is followed by the installation of the power switch and the affixing of labels, preceding the careful positioning and installation of the voltmeter. The voltmeter undergoes a thorough inspection to confirm the dial surface is free of scratches or damage, and that its mounting studs are secure and undeformed. Four M3 hexagonal flange nuts are then used to firmly secure the voltmeter into the upper housing. The process continues with the connection of the wiring, including inserting the locked OT terminal wire into the rocker reset switch and connecting the black spade terminal. The switch is then clipped to the voltmeter, with specific black wire connections from the mica sheet to switch ‘1’ and from the voltmeter to switch ‘O’. The final stage involves verifying that all heat sinks are securely seated, the voltmeter needle is set to zero, and that no scratches or loose components are present. Next, the upper cover is mounted onto the lower cover using four self-tapping screws before the cable clip is secured to both wires leading in and out of the battery tester. The process continues as it moves on to the rack assembly. The left (negative electrode) and right (positive electrode) are affixed using clip screws, followed by tightening of the copper-clad aluminum wire. Upon completion of this stage, the finished product undergoes product testing and calibration. A voltage of 13V is applied to verify the voltmeter’s accuracy to ascertain the reading corresponds to the applied external voltage. The reset switch is pressed and after engaging the load, is released and checked to see the needles spring back to the zero position. The components are then labeled, visually inspected, and the tester packaged and sealed in a cardboard box. When determining the country of origin, 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 origin of the battery tester, in our opinion, the processing in Vietnam is not complex and only enhances the functionality of the Chinese-origin voltmeter. The assembly in Vietnam predominantly involves twisting and encapsulating wires, and fitting components through pressing and screwing. The voltmeter, which provides the essential function of the finished article and is also the most expensive component, is capable of providing all of the required readings when it leaves China. The addition of the Vietnamese components does not create a new article with a name, character, and use different from the Chinese voltmeter, which is still primarily designed to provide electrical readings to the user. Accordingly, the country of origin of the battery tester (model BT103A) is China, which is where the voltmeter is manufactured. 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 Jason Christie at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division