The country of origin of a battery pack

N363513
August 4, 2026
OT:RR:NC:N1:103
CATEGORY: Origin CC Wu PricewaterhouseCoopers Tax Consulting Company, Ltd. 25F, No. 333, Section 1, Keelung Road, Xinyi District Taipei 110 Taiwan RE: The country of origin of a battery pack Dear CC Wu: In your letter dated July 22, 2026, you requested a country of origin ruling on behalf of your client, Trend Power Technology Private Limited Taiwan Branch. The merchandise under consideration is referred to as the Trend Power Lithium-Ion Rechargeable Battery Pack, model number AMZ-01-20SD. It is described as a battery backup unit for data center backup systems and features a durable, box-shaped casing with a handle and a power and signal connector. Inside the case are cylindrical 18650 lithium-ion battery cells and a printed circuit board assembly that functions as a battery management system for monitoring cell voltage, charging current, and temperature. The battery backup unit has a nominal voltage of 49 VDC, a nominal capacity of 7,250 mAh, and a nominal energy of 355 Wh. It measures approximately 85 millimeters in width, 752.7 millimeters in depth, 76.6 millimeters in height, and weighs 7.3 kilograms. The subject battery backup unit is assembled in China using components sourced primarily from China and with battery cells sourced from Malaysia. Minor electrical devices and materials, such as fuses and solder paste, will be sourced from Japan or Taiwan. The printed circuit board assembly, outer case, cable assembly, and remaining components are sourced within China. The process begins with creating a core pack. This involves loading and locking the battery cells into an endcap assembly, spot welding bus plates, and applying glue and insulator paste to the weld joints. Next, the printed circuit board assembly is seated and fastened to the endcap assembly. Workers then install the fuse, solder and inspect string voltage interconnects, install heat-shrink tubing, and apply hot melt reinforcement. Following the creation of the core pack, the assembly process transitions to the final integration phase. This phase involves mounting the core pack in the lower half of the case, installing the cable assembly and fastening its connector to a bracket cover, and installing the top cover. The battery backup unit is subjected to a charge and discharge cycle, as well as functional testing and inspections. Once completed, labels and barcodes are affixed, and the battery is packaged for export.

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 (HQ) 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). Customs and Border Protection has previously held that the assembly of battery cells into battery packs does not result in a substantial transformation. Moreover, there is no significant change in name, use, or character to the battery cells when such an assembly occurs. See HQ ruling 563045, dated August 9, 2004, and HQ ruling 734393 dated March 20, 1992. The assembly operations in China do not change the battery cells, which provide the essential character of the battery backup unit, into an article with a new name, character, or use. The function of the battery cells is to store and provide power, and the function of the battery cells in the battery backup unit is likewise to store and provide power. In view of these facts, and based on the totality of the circumstances, the country of origin of the Trend Power Lithium-Ion Rechargeable Battery Pack, model number AMZ-01-20SD, is Malaysia. 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