HS Code for Lithium-Ion Battery Cell: 8507.60 and the Subheading Trap

Lithium-ion battery cells, modules, and packs are the highest-stakes classification in chapter 85 in 2026. The duty stack on Chinese cells is over 50 percent. The USMCA qualification of advanced batteries decides whether a Tier-1 EV supplier's product can be priced competitively. The Section 232 derivative on the steel or aluminum enclosure adds another 25 to 50 percent on the metal value.

This guide covers HTS 8507.60 in detail, the cell-vs-pack subheading split, the BMS and enclosure classification rules, and the worked tariff math for Chinese, Korean, Vietnamese, and Mexican-assembled batteries.

The heading

HTS 8507 covers electric accumulators. Subheadings:

• 8507.10: lead-acid, starter type.
• 8507.20: other lead-acid.
• 8507.30: nickel-cadmium.
• 8507.40: nickel-iron.
• 8507.50: nickel-metal hydride.
• 8507.60: lithium-ion. The current category of commercial relevance.
• 8507.80: other accumulators.
• 8507.90: parts (separators, electrodes, terminals).

Within 8507.60, the statistical sub-lines split by configuration. CBP statistical annotations for 2026:

• 8507.60.00.10: cells weighing less than 100 grams. Consumer electronics.
• 8507.60.00.20: cells or modules of a kind used in vehicles or grid storage, weighing 100 grams or more.
• 8507.60.00.30: other.

The split matters for ad valorem Section 301 stacking on consumer-grade vs industrial-grade cells and for USMCA chapter 87 advanced-battery determination.

Cell vs. pack classification

A bare cell is 8507.60. A cell with cathode, anode, separator, electrolyte, casing.

A module is multiple cells connected with bus bars but without active BMS. Still 8507.60 because the principal function is energy storage.

A pack with integrated BMS, thermal management, enclosure, terminals, and possibly a junction box is also 8507.60 if the principal function is energy storage. CBP applies General Rule of Interpretation 2(a) to keep the assembly under the same heading.

A pack with non-energy-storage features that dominate (e.g., a power tool that includes a battery but the principal function is the tool) classifies under the tool heading, not 8507. The line is drawn by what the assembly is principally used for.

Worked example: Chinese consumer lithium cells

100,000 USD of HTS 8507.60.00.10 (cells under 100 grams) from a Chinese cell maker. Used in consumer electronics.

Effective rate 45.7 percent. The Chinese cell economics in consumer electronics have shifted dramatically; Korean LG and Samsung SDI cells, Japanese Panasonic cells, and Vietnamese-assembled (with Chinese cathode active material) packs all compete against the 50 percent China stack.

Worked example: Korean lithium pack for EV

200,000 USD of HTS 8507.60.00.20 (vehicle-grade) from LG Energy Solution Korea. USMCA-region assembly not applicable here (direct Korean import).

Effective rate 21.2 percent. KORUS waives the MFN duty but does NOT carve out Section 122, so Korean cells still pay the 10 percent surcharge. The Section 232 derivative on the steel enclosure portion stacks on top. Korean cells still beat the Chinese stack because the Section 301 layer is absent.

Worked example: Mexican-assembled EV battery pack

A Mexican Tier-1 supplier assembles a 100 kWh EV battery pack for a US OEM. HTS 8507.60.00.20. Pack transaction value 12,000 USD. BOM:

USMCA RVC test for vehicle-use advanced batteries (treated as core parts under the chapter 87 supplemental rule):

Non-originating materials: 6,800 (cells; Chinese cathode origin governs even though Korean assembly).

RVC (TV) = (12,000 minus 6,800) divided by 12,000 = 43.3 percent.

This pack does NOT qualify for USMCA. The 75 percent threshold is far off. The cells are too large a share of value to qualify with imported active material.

Untold story: this is the core problem facing the North American EV supply chain in 2026. Most Tier-1 producers cannot source cells from a USMCA-qualifying cathode active material producer at scale yet. The IRA and USMCA together push toward NA cathode production but capacity is still ramping. Until ramp completes, EV batteries land in the US with full duty.

Note Mexico is at 0 percent Section 122 regardless of USMCA qualification, because Mexico's bilateral relationship under USMCA framework keeps the 122 layer suppressed for goods from Mexico generally. The duty hit on a non-USMCA-qualifying Mexican-assembled pack is mostly the Section 232 derivative on the metal enclosure plus the MFN.

Effective rate roughly 10 percent. Lower than the Chinese-cell direct import at 50 percent and lower than the Korean direct import at 11 percent. Mexican assembly with Chinese or Korean cells wins on landed cost even without USMCA qualification, IF the cells are sourced from outside China to dodge the China-specific stack.

Section 232 derivative on enclosures

Lithium battery packs almost always have a metal enclosure. Steel cross-bracing under HTS 7308 and aluminum housing under HTS 7616 both fall into the Section 232 derivative annex. The duty applies to the metal-content value portion only.

The producer affidavit identifies the metal value share. For a typical EV pack, the metal value is 8 to 15 percent of pack value. The Section 232 share at 50 percent on the metal value is then 4 to 7.5 percent of pack value.

Missing the affidavit defaults to 100 percent metal classification, multiplying the duty by 6 to 12x.

Documentation pitfalls

• Misclassifying a battery pack as the device it powers (the tool, the laptop, the car). The pack always classifies under 8507 if it is the principal energy storage component.
• Splitting a pack assembly across multiple HTS lines on a per-component basis when a single 8507.60 line is correct.
• Failing to declare cathode active material origin separately. CBP increasingly asks for the cathode origin specifically due to the USMCA chapter 87 advanced-battery rule.
• Combining the BMS into 8507.60 when the BMS is a separate sub-assembly being imported alone (should be 8537 in that case).

Run your battery pack entry now

The LandedFees calculator handles 8507.60 with the cell-vs-pack subheading split, the Section 232 derivative metal-value calculation, the USMCA RVC test including the chapter 87 advanced-battery rule, and the Section 301 + Section 122 stack on Chinese cells.

Calculate a battery pack shipment

Section 122 status as of June 20 2026

The May 7 2026 Court of International Trade ruling in Oregon v. United States (consolidated with Burlap and Barrel v. United States) struck down the Section 122 proclamation. The Federal Circuit issued an administrative stay on May 12 2026, so CBP is still collecting the duty pending appeal. Importers paying now should preserve protest rights and refund claims in case the government loses on the merits. The underlying Section 122 authority sunsets July 24 2026 under the statutory 150-day ceiling, regardless of the appeal outcome, unless Congress extends or a fresh proclamation restarts the clock.

Citations

• USITC Harmonized Tariff Schedule heading 8507: https://hts.usitc.gov/?query=8507
• USMCA chapter 87 advanced battery rule: USMCA Annex 4-B Appendix
• Section 232 derivative annex: Federal Register 2025 expansion
• USTR Section 301 List 3 covering chapter 85: https://ustr.gov/issue-areas/enforcement/section-301-investigations
• KORUS lithium battery tariff schedule: USTR FTA texts