The country of origin of an E-bike

N350306 July 3, 2025 OT:RR:NC:N2:201 CATEGORY: Origin Timothy Stevens Radio Flyer Inc. - Chicago, IL 6515 West Grand Ave Chicago, IL 60707-3436 RE: The country of origin of an E-bike Dear Mr. Stevens: In your letter dated June 16, 2025, you requested a country of origin ruling on an E-bike assembled in Cambodia and China with a Cambodian produced frame. The item under consideration has been identified as the Flyer Via Pro R E-bike (Model 886). The lithium battery-powered bicycle is equipped with an electric motor and standard bicycle drivetrain components. It has pedal-assist and throttle functionality. In your request you state that the E-bike frame has been 100% manufactured in Cambodia. Included in your submission is the company profile, licensing documents, bill of materials, and photographs of the facility. You provided a YouTube video showing the manufacturing process from straight tubes to a finished frame. You state that all components and material in the manufacturing process were sourced in China. The assembly process takes place in Cambodia and China. Raw aluminum tubes are first extruded in China and then shipped to Cambodia. In Cambodia, the tubes undergo a multiple complex manufacturing process: • Precision bending, cutting, and forming • Welding into a complete bicycle frame structure • Heat treatment to strengthen the welded frame • Dimensional adjustments to meet tolerance specifications • Final painting and surface finishing • Final Assembly and Component Integration (China): The completed and painted frame is then exported to China, where it is received by the finished goods assembler. At this facility: • Electrical components, including the lithium battery, motor controller, and display, are sourced from local Chinese suppliers. • Mechanical parts such as the shifter, brakes, saddle, wheels, and drivetrain are also locally sourced. • The assembler performs assembly, component integration, tuning, and final complete packaging of E-bikes for export/U.S.A. When determining the country of origin, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). It is the opinion of this office that, based on the information provided, the processes that take place in Cambodia substantially transform the individual components sourced from China to complete the E-bikes. These processes are sufficiently complex and meaningful and result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of new articles, possessing new names, characters and uses. Therefore, it is our opinion that the country of origin for the Flyer Via Pro R E-bike (Model 886) will be Cambodia. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Matthew Sullivan at matthew.sullivan@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division