CLA-2-85:OT:RR:NC:N1:103
Andrew Lam
Elala Distribution Corp.
58 S 5th St., Apt. F
Alhambra, CA 91801
RE: The tariff classification of a battery pack from China
Dear Mr. Lam:
In your letter dated March 19, 2025, you requested a tariff classification ruling.
The merchandise under consideration is referred to as a rechargeable lithium-ion battery pack, model number
EL-2500-PB1, which is described as a portable device for storing and supplying electricity. It consists of
twelve cylindrical battery cells enclosed in a rectangular housing with a built-in USB-C cable, DC connector
port, RC connector port, power button, and LED indicator lights. The battery pack has an output voltage of 5
VDC (USB-C), an output voltage of 37 VDC (DC port), a nominal capacity of 2600 mAh, and a nominal
energy of 96.2 Wh. The battery pack is used to power electric luggage scooters but can also be used to power
electronic devices, such as tablets and smartphones.
The applicable subheading for the lithium-ion battery pack, model number EL-2500-PB1, will be
8507.60.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric
storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof:
Lithium-ion batteries: Other.” The general rate of duty will be 3.4 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8507.60.0020, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8507.60.0020, HTSUS, listed above.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8507.60.0020, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS
and the accompanying duty rates are provided at https://hts.usitc.gov/.
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,
Steven A. Mack
Director
National Commodity Specialist Division