OT:RR:NC:N2:207
Gena Haddock
Expeditors Tradewin, LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin of a portable solar panel
Dear Ms. Haddock:
In your letter dated January 13, 2026, you requested a country of origin ruling for portable solar panels on
behalf of your client, BioLite Energy.
The merchandise under consideration is referred to as a portable solar panel, Model Name Goal Zero Nomad
200+ (NMC0100). The article is a foldable solar charger designed to generate electricity to charge various
personal devices such as smartphones, tablets, and laptops, as well as optional Goal Zero Yeti Power Stations
(Portable Power Station). The panel consists of four (4) monocrystalline silicon solar modules encased within
a weather-resistant fabric enclosure. It is equipped with a High Power Port for charging portable power
stations and a USB-A port for personal devices. We note that the solar charger does not store energy but is
designed to generate power when exposed to sunlight.
In use, the solar panels are unfolded and placed on the ground using the provided kickstand. Then either the
portable power station or personal device is connected to the charging ports on the back of the panel. The
solar charger consists of four 50W solar panels, yielding a maximum output of 200W.
You state that the manufacturing process begins in China where the wafers for solar cells are manufactured.
A monocrystalline silicon ingot is grown in China and sliced into thin wafers using wire saws. The finished
wafers are shipped to Indonesia for further processing. In Indonesia, the Chinese wafers are diffused with
boron on the front-side of the wafer to create the P-type emitter layer. Then an ultra-thin tunnel oxide and
phosphorus-doped polysilicon layer is deposited on the rear surface using low-pressure chemical vapor
deposition to create the TOPCon or N-Type structure,x` thereby creating the P/N junction within the solar
cells.
The finished solar cells are cut to desired size and laminated using Ethylene Vinyl Acetate (EVA) sheets for
the top and a Polyethylene Terephthalate (PET) layer for the back, providing a rigid structure for protection
and durability. Then, the solar panels are encased in a weather-resistant fabric enclosure, and a mesh pouch
with a junction box from China are added to the back along with a kick stand. The completed solar panels are
tested and packaged for shipment to the United States.
When determining the country of origin for purposes of applying current trade remedies under Section 301,
Section 201 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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country of origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
Regarding the country of origin of the portable solar panel, the raw wafers of Chinese origin are substantially
transformed in Indonesia to create solar cells with a new name, character and use. Furthermore, it is the
opinion of this office that the finished solar cells establish the function of the solar panels by creating
electrical current when exposed to light. Lastly, the addition of a junction box with charging ports, kick stand
and fabric enclosure of Chinese origin does not substantially transform the solar cells into a new and different
article. As such, this office finds that the Goal Zero Nomad 200+ (NMC0100) is considered a product of
Indonesia for origin and marking purposes at the time of importation into the United States
You have asked whether this product is subject to antidumping duties or countervailing duties (AD/CVD).
When there is a question as to whether merchandise is subject to an antidumping or countervailing duty order
or considered to be defined by the scope of an order, such a determination is governed by the U.S.
Department of Commerce’s International Trade Administration (“Commerce”). Commerce issues scope
rulings to determine whether merchandise which is in commercial production is covered by the scope of an
antidumping or countervailing duty order. Commerce’s scope rulings are separate and distinct from decisions
issued by CBP regarding tariff classification and country of origin for purposes such as duty assessment and
marking.
To seek a scope ruling, please visit the website of Commerce’s International Trade Administration. A guide
to seeking a scope ruling can be found at
https://access.trade.gov/help/Scope_Ruling_Guidance_(4.1.2022).pdf. A list of current AD/CVD
investigations at the United States International Trade Commission can be viewed on its website at
http://www.usitc.gov. Additionally, messages sent by Commerce to CBP regarding AD/CVD cash deposits
and liquidation can be searched using ACE or CBP’s search tool at
https://trade.cbp.dhs.gov/ace/adcvd/adcvd-public/#.
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 Howard Suh at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division