The country of origin of battery charger for power tools

N361360May 21, 2026OT:RR:NC:N2:207
CATEGORY: OriginWilliam MaloneySandler, Travis & Rosenberg, P.A.286 Madison Avenue - Suite 1200New York, NY 10017RE: The country of origin of battery charger for power toolsDear Mr. Maloney:In your letter dated
May 7, 2026
, you requested a country of origin ruling on a battery charger on behalf ofyour client, Panasonic Industrial Devices Slovakia s.r.o.The merchandise under consideration is described as Li-Ion battery charger, which is identified by ModelNumber ETY1HL222xx-S. The battery charger is comprised of a Printed Circuit Board Assembly (PCBA)which facilitates the charging functionality, terminals (battery contact points), LED indicator for batterycharge status, radial cooling fan and a power cord. The output power is 240W (DC) with output current at 9.6A (DC) along with rated input voltage of 115V (AC). There may be a variation of the same battery chargerwith a 220-240V (AC) for European models. The battery charger is designed to charge Li-Ion batteriescommonly used with power tools. We note that the batteries are not included at time of importation.You state that the manufacturing process begins in Slovakia producing the finished PCBA using a widevariety of electronic components (integrated circuits, transformers, capacitors, resistors, diodes) sourced fromvarious countries including China, Japan, the Philippines, Thailand, Taiwan, and Malaysia, among others. Ablank Printed Circuit Board (PCB) from China is populated with numerous electronic components using acombination of the Surface Mount Technology (SMT) process and through-hole soldering process dependingon the type of electronic components. Then the PCBA is inspected, tested, and programmed with firmware.The finished PCBA is exported to China for further assembly.In China, the PCBA from Slovakia is assembled into a plastic housing of Chinese origin along with a coolingfan and an AC power cord from China. The finished battery charger is tested and packaged for shipment intothe United States. 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 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).Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unlessexcepted, every article of foreign origin imported into the United States shall be marked in a conspicuousplace as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such amanner as to indicate to the ultimate purchaser in the United States, the English name of the country of originof the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should beable to know by an inspection of the marking on the imported goods the country of which the goods is theproduct. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking shouldinfluence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements thecountry of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBPRegulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, orgrowth of any article of foreign origin entering the United States. Further work or material added to an articlein another country must effect a substantial transformation in order to render such other country the “countryof origin” within the meaning of the marking laws and regulations.Regarding the country of origin of the battery charger, the bare PCB of Chinese origin is substantiallytransformed into a functional PCBA when individual electronic components from various countries aremounted and soldered onto the PCB using the SMT and through-hole soldering processes. Furthermore, it isthe opinion of this office that the PCBA is the dominant component that provides the character of the finishedarticle as it is a fully functional charging control unit that converts AC power to regulated DC current,manages Li-Ion charging profiles, and provides safety and fault-protection for the battery packs. Assembly ofplastic housing, cooling fan and power cord in China is not complex enough to constitute a substantialtransformation. As such, the country of origin of the Li-Ion battery charger will be Slovakia for origin andmarking purposes.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 Howard Suh at [email protected].
Sincerely,
(for)James P. ForkanDirectorNational Commodity Specialist Division