Portable lithium-ion power bank, 10,000 mAh, with dual USB output ports and LED charge indicator

GRI Reasoning

Step 1 — GRI 1: Heading identification

The product is a portable lithium-ion power bank: a rechargeable lithium-ion accumulator in a housing with dual USB output ports and an LED charge indicator. The essential function is storing electrical energy and delivering it to external devices.

Heading 8507 covers "Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof." EN to 8507 and consistent CBP precedent confirm that portable power banks — even those incorporating ancillary charging circuitry — are classified here because the battery/accumulator function is the article's defining character.

Heading 8504 covers "Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof." In HQ H298118, CBP directly addressed and rejected the argument that a portable power bank with USB output and an LED indicator is a static converter under 8504.40.95, affirming classification under 8507.60.00. H342925 (2026) further clarifies that only where the charger component dominates a set (and the battery cannot supply power to other apparatus independently) does 8504 prevail — a fact pattern not present here, as this power bank is a standalone device that supplies power to external devices.

Step 2 — GRI 1: Subheading 8507.60.00

Among the subheadings of 8507, subheading 8507.60.00 specifically covers "Lithium-ion batteries." The product contains a lithium-ion cell; classification at the 6-digit level is unambiguous.

General rate of duty: 3.4% ad valorem (as stated in the supplied HTS row for 8507.60.00).

Step 3 — GRI 6: Statistical suffix selection

Under 8507.60.00, the supplied HTS rows show three statistical breakouts:

• 8507.60.00.10 — Of a kind used as the primary source of electrical power for electrically powered vehicles of subheadings 8703.40–8703.80 → Not applicable.
• 8507.60.00.30 — Battery energy storage systems fully encased within a housing, as described in statistical note 2 to this chapter → A consumer 10,000 mAh power bank is not a utility-scale battery energy storage system within the meaning of statistical note 2.
• 8507.60.00.90 — Other → Correct breakout for a portable consumer power bank.

Note: Candidate codes 8507.60.0020 and 8507.60.0040 cited in rulings N288408 and N306841 reflect a prior schedule structure; the current supplied HTS rows do not contain those suffixes. The deepest code present in the supplied evidence for this article is 8507.60.00.90.

Step 4 — Chapter 99 Section 301 overlay

The supplied HTS row for 8507.60.00 carries footnotes referencing 9903.88.15 and 9903.91.06 as additional-overlay flags. Per ruling N306841, goods of China classified under 8507.60.00.90 are subject to an additional Section 301 duty under 9903.88.15 (rate stated in supplied Chapter 99 rows as "the duty provided in the applicable subheading plus" an additional percentage). Importers must report 9903.88.15 at entry in addition to 8507.60.00.90. The rate for 9903.88.15 is not independently quoted as a flat number in the supplied evidence; it must be verified against the current Chapter 99 schedule at time of entry. Additionally, 9903.91.06 should be checked as a potential overlay at time of importation.

Step 5 — Duty estimate

• Base general rate: 3.4% ad valorem
• Section 301 overlay: 9903.88.15 applies (flag to verify current rate at entry)
• Declared unit value: $8.90 × 12,000 units = $106,800 annual import value
• At 3.4% base: ~$3,631 base duty annually (exclusive of Section 301 additional duty)

Summary

Classification under 8507.60.00.90 is supported by GRI 1, four directly on-point CBP rulings, and the plain terms of the heading. The 8504.40.95 alternative is expressly foreclosed by HQ H298118.