The country of origin of an automotive battery assembly

N361091May 14, 2026OT:RR:NC:N1:103
CATEGORY: OriginStefan SchneiderHandtmann Systemtechnik GmbH & Co. KGArthur-Handtmann-Str. 7/1Biberach 88400GermanyRE: The country of origin of an automotive battery assemblyDear Mr. Schneider:In your letter dated
April 29, 2026
, you requested a country of origin ruling.The merchandise under consideration is identified as a 48 V lithium-ion automotive battery pack, modelnumber BB500, with a nominal capacity of 30 Ah and a nominal energy of 1,300 Wh. The battery packconsists of a high-voltage lithium-ion battery module, a battery management system, and a structural castaluminum housing with integrated cooling channels.The high-voltage battery module is sourced from China and is described as a group of prismatic battery cellsarranged in a 12S1P configuration. The remaining components are sourced from Germany, Hungary,Slovakia, Switzerland, and Turkey. These include a German aluminum battery housing, a Hungarian batterymanagement system with DC converter, a Slovakian busbar module, and other components.Final assembly occurs in Germany, and begins with inspecting the battery module, applying thermaladhesive, and mounting the module in the housing. In a separate compartment within the housing, the batterymanagement system and its connectors are mounted and then connected to the battery module. The top coveris fitted to the housing, and a bead of glue is applied around the perimeter to seal the assembly. Lastly,workers load the software for the battery management system and complete testing.When determining the country of origin for purposes of applying current trade remedies under Section 301and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters RulingLetter H301619, dated November 6, 2018. The test for determining whether a substantial transformation willoccur is whether an article emerges from a process with a new name, character, or use different from thatpossessed 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).
U.S. Customs and Border Protection has previously held that the assembly of battery cells into a battery packdoes not result in a substantial transformation of the battery cells because the essential character of the cellsdoes not change simply by being placed together in a housing. See HQ ruling 563045, dated August 9, 2004,and HQ ruling 734393, dated March 20, 1992. Here, the Chinese battery cells are assembled into a batterymodule prior to arrival in Germany, and its function is to store and supply power. The function of the batterymodule remains unchanged after installation in the housing. In view of these facts, and based on the totalityof the circumstances, the country of origin of the 48 V lithium-ion automotive battery pack, model numberBB500, is China.The holding set forth above applies only to the specific factual situation and merchandise description asidentified 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 theinformation furnished in the ruling letter, whether directly, by reference, or by implication, is accurate andcomplete in every material respect. In the event that the facts are modified in any way, or if the goods do notconform to these facts at time of importation, you should bring this to the attention of U.S. Customs andBorder 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 periodicverification by CBP.This ruling is being issued under the provisions of Part 177 of the Customs and Border ProtectionRegulations (19 C.F.R. 177).A copy of the ruling or the control number indicated above should be provided with the entry documentsfiled at the time this merchandise is imported. If you have any questions regarding the ruling, please contactNational Import Specialist Paul Huang at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division