CLA-2-85:OT:RR:NC:N1:103
Jose Vera
NTG Air Ocean LLC
357 Van Ness Way, Ste. 10
Torrance, CA 90501
RE: The tariff classification of battery packs from China
Dear Mr. Vera:
In your letter dated June 11, 2025, you requested a tariff classification ruling on behalf of your client, Era
Nouveau Holdings dba Enouvation.
The first item under consideration is referred to as the Enouvation E5 power pack, model number
ENBATTE57S1P, and is described as a battery pack for power motion recliners, reclining sofas, or loveseats.
It consists of lithium-ion pouch cells encased in a plastic housing with an LED indicator, a manual power
switch, a cable with a barrel jack input connector, and a cable with a two-pin output connector. The power
pack has a nominal voltage of 25.9 VDC, a nominal capacity of 5,000 mAh, and a nominal energy of 129.5
Wh.
The second item under consideration is referred to as the Enouvation E10 power pack, model number
ENBATTE107S2P, and is described as a battery pack for power motion sectionals. It consists of lithium-ion
pouch cells encased in a plastic housing with an LED indicator, a manual power switch, a cable with a barrel
jack input connector, and a cable with a two-pin output connector. The power pack has a nominal voltage of
25.9 VDC, a nominal capacity of 10,000 mAh, and a nominal energy of 259 Wh.
In your submission, you inquire whether the subject power packs are classifiable in heading 8517,
Harmonized Tariff Schedule of the United States (HTSUS). While the subject power packs may incorporate
Bluetooth technology for communication, the principal function of the power packs is to store and supply
electricity.
The applicable subheading for the E5 power pack, model number ENBATTE57S1P, and the E10 power
pack, model number ENBATTE107S2P, will be 8507.60.0020, 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.
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.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading
8507.60.0020, HTSUS, listed above.
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.
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.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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,
(for)
James Forkan
Acting Director
National Commodity Specialist Division