Exporting Battery Cells vs Finished Systems: Customs
One of the biggest distinctions lies in whether you are exporting individual battery cells or finished energy storage systems (ESS).
SPECIFIC CUSTOMS CODE FOR ENERGY STORAGE The HS code that typically pertains to energy storage systems, particularly lithium-ion or lead-acid batteries, is 8507.60. This designation covers various types of batteries utilized in energy storage applications, playing a vital role in commercial and residential energy systems.
After the subject lithium-ion battery is imported into the United States, it will be incorpo-rated into a residential energy storage solution, which requires a battery management system, additional battery units, enclosures, and other com-ponents.
You suggest the subject lithium-ion battery pouch cell is classified under subheading 8507.60.0010, Harmonized Tariff Schedule of the United States (“HTSUS”). Although we agree the subject battery pouch cell is classified in heading 8507, HTSUS, we disagree on the subheading.
It is now CBP's position that Lithium-Ion Battery Cells are properly classified, in heading 8507, HTSUS, specifically in sub-heading 8507.60.00, HTSUS, which provides for “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Lithium-ion batteries.”
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