NCS/ARS/CL/10221

You have requested for the Tariff Classification for Lithium Battery Component Parts for Assembly.

These components are essential in the manufacture and assembly of lithium batteries, such as those used in energy storage systems, electric vehicles, or portable electronics.

The Working Principles 

As contained in the submitted documents, the following are the functions of each component:

1. Lithium Battery Cells (Primary Components): are electro-chemical cells containing lithium-based chemistry which may be cylindrical, pouch, or prismatic in form and serves as the energy storage core in the battery pack.
2. Battery Casing (Housing or Enclosure): are metal or plastic enclosures that house battery cells and electronic control boards which provide mechanical protection, thermal management, and mounting interfaces.
3. Circuit Board (Battery Management System Board or BMS): is a dedicated BMS board for managing charging, discharging, balancing, and protection of lithium cells which may include components for communication, voltage sensing and temperature monitoring. 
4. Epoxy Board (Insulating Board): is a fiberglass-reinforced epoxy resin board used for electrical insulation between battery components and often made of FR4 (flame-retardant) material, used for mechanical and dielectric isolation.
5. PCB Board (Printed Circuit Board for Battery Connector/Signal Routing): is a custom PCB designed for internal battery interconnects or communication between modules which may support connectors, fuses, signal paths, or low-voltage power control.

Note that, as stated in the proforma invoice, these components are being purchased individually and not as a set.

CLASSIFICATION

The Epoxy Board which has been cut to size for assembly of the Lithium battery, will be classified under Subheading 8507.90 as a part of an electrical accumulator based on the General Explanatory note, which states that “Subject to the general provisions regarding the classification of parts (see the General Explanatory Note to Section XVI), the heading also covers parts of accumulators, e.g., containers and covers; lead plates and grids, whether or not coated with paste; separators of any material (except of unhardened vulcanized rubber or of textile material), including those in the form of flat plates merely cut into rectangles (including squares), meeting very precise technical specifications (porosity, dimensions, etc.) and hence ready for use”.

Accordingly, the products under review are effectively classified as follows in the ECOWAS CET 2022 – 2027.

1. Lithium Battery Cells - 8507.60.00.00 - Lithium-ion accumulators with a 20% duty rate and 7.5% VAT
2. Battery Casing - 8507.90.00.00 - Parts of electric accumulators with a 10% duty rate and 7.5% VAT
3. Circuit Board - 8537.10.00.00 - Boards, panels, consoles... for electric control/distribution. For a voltage =< 1,000 V with a 5% duty rate and 7.5% VAT
4. Epoxy Insulation Board - 8507.90.00.00 - Parts of electric accumulators with a 10% duty rate and 7.5% VAT
5. PCB Board -  8534.00.00.00 - Printed circuits with a 5% duty rate and 7.5% VAT

Legal Framework and Justification

GIR 1 and 6