OT:RR:NC:N2:220
Friederike Goergens
Greenberg Traurig LLP
2101 L Street
Washington, DC 20007
RE: The country of origin of the Portable Storage Generator
Dear Mr. Goergens:
In your letter dated May 9, 2025, you requested a country of origin ruling on behalf of your client, Jackery,
Inc.
The merchandise under consideration is identified as the Portable Solar Generator, Model
HTE1172000A-US-JAK (“E2000v2”), which is described as an electrical storage and distribution machine
that incorporates a converter, inverter, multiple output connections, and is equipped with a bank of lithium
iron phosphate (LiPO) batteries. On the front face of the E2000v2 is a small LCD screen, three NEMA
15-20R electrical sockets for AC output, one USB-A/two USB-C sockets for DC output, one 12 VDC
accessory socket, a LED area light, and control buttons. On the right side of the unit are three input sockets,
one AC and two DC. The LCD displays electrical input/output, performance data, connectivity (wireless
and/or Bluetooth), environmental information, and stored power data. Internally, the E2000v2 consists of the
housing components, the LiPO battery bank, six printed circuit board assemblies (PCBAs), numerous
electrical connectors and/or bus bars, and insulators.
In use, the E2000v2 is connected to a power source to store electricity, where users have the ability to access
the stored power through connected machines and appliances. While the E2000v2 is described in your letter
as a “solar charger”, we note that the unit can receive input mains AC power, DC power from a DC
generating device, such as a photovoltaic generator, or even a vehicle’s DC power, if so equipped.
You identify the PCBAs as the Mainboard, the Battery Protection Board, the AC Adapter Board, the DC
Adapter Board, the Module Adapter Board, and the Inverter. You describe the Mainboard as being
responsible for controlling the logic of each module in the system, providing electrical protection, and
providing intelligent control. The Battery Protection Board is described as the core control unit that controls
the functions of the batteries, monitors, and provides electrical protection to the battery pack. The AC
Adapter Board is described as providing a parallel circuit connection for the front AC sockets. The DC
Adapter Board is described as integrating low-voltage DC charging and transfer functions. The Mobile
Adapter Board is described as monitoring the battery cell voltages and temperatures, transmitting the values
to the battery management system. And the Inverter is described as performing conversion of electricity,
such as the AC to DC and DC to AC conversions, and performing voltage step up/down. Each of the PCBAs
identified above are manufactured by soldering individual components, such as resistors, capacitors,
integrated circuits, transformers, etc. onto bare printed circuit boards through a surface mount and/or
through-hole insertion process.
In your submission, you provide four scenarios of where the PCBAs are manufactured and the E2000v2 is
assembled. In the first scenario, the Mainboard, the Battery Protection Board, the AC Adapter Board, the DC
Adapter Board, and the Module Adapter Board are being manufactured in China. The Inverter is said to be
manufactured in Japan. In China, the boards and structural components are assembled with the Chinese
origin batteries by inserting, fastening, mounting, etc. to produce a functional electrical storage, converter,
and distribution machine. Also in China, the E200v2 is tested and packaged for export to the United States.
In the second scenario, the Mainboard, the Battery Protection Board, the AC Adapter Board, the DC Adapter
Board, and the Module Adapter Board are being manufactured in Vietnam. The Inverter is said to be
manufactured in Japan. In China, the boards and structural components are assembled with the Chinese
origin batteries by inserting, fastening, mounting, etc. to produce a functional electrical storage, converter,
and distribution machine. Also in China, the E200v2 is tested and packaged for export to the United States.
In the third scenario, the Mainboard, the Battery Protection Board, the AC Adapter Board, the DC Adapter
Board, the Module Adapter Board, and the Inverter are being manufactured in Vietnam. In China, the boards
and structural components are assembled with the Chinese origin batteries by inserting, fastening, mounting,
etc. to produce a functional electrical storage, converter, and distribution machine. Also in China, the
E200v2 is tested and packaged for export to the United States.
In the fourth scenario, the Mainboard, the Battery Protection Board, the AC Adapter Board, the DC Adapter
Board, and the Module Adapter Board are being manufactured in China. The Inverter is said to be
manufactured in Vietnam. In Vietnam, the boards and structural components are assembled with the Chinese
origin batteries by inserting, fastening, mounting, etc. to produce a functional electrical storage, converter,
and distribution machine. Also in Vietnam, the E200v2 is tested and packaged for export to the United
States.
When determining the country of origin, the substantial transformation analysis is applicable. See, e.g.,
Headquarters Ruling Letter (“HQ”) 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).
Regarding the origin of the E2000v2 for scenarios one and four, the assembly of the PCBAs by soldering the
individual components of various origins onto bare printed circuit boards in China results in a substantial
transformation of those components to produce five PCBAs of Chinese origin. While the Inverter PCBA,
which is produced in Japan for scenario one and Vietnam for scenario four, is an important component of the
E2000v2, in our view, the Mainboard, Protection, and Adapter PCBAs, as well as the Chinese batteries,
establish the bulk of the functionality of the E2000v2. As a result, the Portable Solar Generator, Model
HTE1172000A-US-JAK, described in scenarios one and four are considered products of China at the time of
importation into the United States.
Likewise, in scenarios two and three, the assembly of the PCBAs by soldering the individual components of
various origins onto bare printed circuit boards in Vietnam results in a substantial transformation of those
components to produce five PCBAs of Vietnamese origin. As with scenarios one and four, the Inverter
PCBA that is produced in Japan for scenario two and Vietnam for scenario three is an important component
of the E2000v2, the Mainboard, Protection, and Adapter PCBAs, as well as the Chinese origin batteries,
establish the bulk of the functionality of the E2000v2. As a result, the Portable Solar Generator, Model
HTE1172000A-US-JAK, described in scenarios two and three, are considered products of Vietnam at the
time of importation into the United States.
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 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 Karl Moosbrugger at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division