The country of origin of a lithium-ion portable jump starter and battery pack

N362495
July 9, 2026
OT:RR:NC:N1:103
CATEGORY: Origin Selina Huang Bolt Power Energy Co., Ltd. 99/46, Moo 8, Tamboon Takham, Amper Bangprakong Chachoengsao 24130 Thailand RE: The country of origin of a lithium-ion portable jump starter and battery pack Dear Ms. Huang: In your letter dated June 23, 2026, you requested a country of origin ruling. The portable jump starter and battery pack, model number K23, consists of a lithium-ion battery pack encased in a two-piece plastic housing with a power button, LED lamp, USB-A output port, and USB-C input charging port. It has a 10,000 mAh capacity, a nominal voltage of 14.8 VDC, an energy capacity of 38.5 Wh, and is designed to provide up to 1,000 peak amps. This device also serves as a power bank, charging electronic devices via its USB-A port. The jump starter will be assembled in Thailand using Chinese and Thai components. The Thai components include a printed circuit board assembly (PCBA), an upper plastic shell, and a lower plastic shell. The main Chinese components include the lithium-ion pouch cells, an LED lamp, a USB charging cable, and a booster cable with alligator clamps. Additional components, such as silicone covers for the ports, a light reflector, lens, screws, wires, and tape, are also sourced from China. The assembly process begins in Thailand with workers bundling four battery cells together, soldering a wire assembly with a terminal pin connector, soldering a wire assembly with an EC5 receptacle, and applying heat shrink. The finished battery pack is connected to the PCBA, and both components are secured to the lower shell using screws. Next, the LED lamp assembly, which allows the jump starter to function as a light source, is connected to the PCBA. Anti-slip pads are attached to the upper shell, which is then fastened to the lower shell with screws. The assembled unit is inspected, tested, labeled, and packaged with the detachable booster cable and a USB charging cable. 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 Thailand are not complex. Turning to the components of the jump starter, we find that the primary components are the Chinese battery cells, which perform the principal function of maintaining an independent source of electricity to deliver sufficient current to start automotive vehicles or charge electronic devices. Therefore, based on the totality of the circumstances, the country of origin of the subject portable jump starter, model number K23, is China. 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) James P. Forkan Director National Commodity Specialist Division