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CBP ruling request template for batteries

Planning Use only. Broker review required for Entry Use.

Battery ruling requests fail when the file says "lithium battery" and nothing else. CBP needs a much tighter product story: chemistry, form, electrical capacity, pack construction, safety electronics, and whether the battery ships by itself or inside a device.

quick answer

For cbp ruling request template batteries, prepare the request around the exact battery architecture. A coin cell, lead-acid replacement battery, rechargeable lithium-ion pack, power bank, and battery shipped with a tool can move through different HTS candidate families. Do not treat a supplier HS code as enough. Build a Planning Use record, then send the fact set to a Broker or ruling reviewer.

facts to collect before drafting

Battery chemistry: lithium-ion, lithium polymer, primary lithium, alkaline, lead-acid, nickel metal hydride, or another chemistry.
Form: individual cell, assembled pack, battery module, power bank, replacement battery, or battery inside another article.
Voltage, capacity, watt-hour rating, amperage, number of cells, and whether the pack includes a battery management system.
Housing material, terminals, connectors, charger, adapter, cables, fuses, or protective circuit board.
Device relationship: sold alone, packed with a device, installed in a device, or imported as a spare part.
Safety documents such as SDS, UN38.3 test summary, product photos, label art, and technical datasheet.
Origin evidence for cells, pack assembly, circuit board assembly, and final testing.

missing facts

The Missing Facts section should call out anything that can change the code path. Do not hide vague phrases such as rechargeable battery pack or battery for electronics. Ask whether the article has USB output, inverter function, charging circuitry, solar input, or a case that changes its retail identity. If origin is unclear, separate cell origin from pack assembly and final inspection.

HTS candidate notes

Start with battery provisions in the USITC HTS, then test whether the article is really a battery, a part of a machine, or a device with a battery included. A pack with output ports may need different treatment than loose cells. A battery embedded in a finished appliance may follow the appliance if the battery is imported with it. Section 301 exposure can also depend on origin and exact subheading.

authority sources

Use CBP CROSS for fact patterns, not for copy-paste certainty. A ruling on a lithium battery pack only helps if the chemistry, output, casing, use, and import condition match.

planning path

Write the request in a plain sequence: what the article is, what documents prove it, which HTS families were considered, which facts separate those families, and what review decision is requested. Keep supplier claims in a separate note unless they are backed by documents.

Add a one-page appendix for labels and battery markings. Model number, capacity, recycling marks, warning labels, and certification marks should match the spec sheet.

questions importers ask

Can a UN38.3 report prove the HTS code?

No. It helps identify the battery and shipping risk, but it does not decide classification by itself.

Should the request include the device powered by the battery?

Yes, if the battery is imported with, inside, or for a specific device. That relationship can matter.

Can the supplier code go in the record?

Yes, but label it as supplier-provided. The record still needs official source review.

internal links

planning boundary

This batteries page is a planning artifact. It is not an Entry Use classification, not a binding ruling, and not a legal opinion. The importer remains responsible for reasonable care and must obtain broker or customs authority review before filing.

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