The country of origin of an electric scooter

N356467 December 22, 2025 OT:RR:NC:N2:201 CATEGORY: Origin Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of an electric scooter Dear Ms. Murrin: In your letter dated November 26, 2025, you requested a country-of-origin ruling on an electric scooter, on behalf of your client Segway, Inc. In your request, you state that the electric scooters are manufactured and assembled in Vietnam. You express that the basic frame components are obtained through the aluminum extrusion process. It then undergoes shaping/correction via CNC machining. The frame is then inspected. You present documents and a video/compact disc showing the production work done in Vietnam. You provided a Bill of Material (BOM) showing the country of origin of all components and materials used in the manufacturing process. The MAX G3 electric scooter is a two-wheeled stand-up scooter. It is equipped with a: 2,000-watt motor Maximum speed of 28 mph\ Range of up to 50 miles\ Battery capacity of 597 WH (watt-hours) In your production video you show that raw aluminum alloy is extruded into a frame component in Vietnam. It undergoes the following manufacturing processes: CNC machining and inspection in Vietnam. The manufacturing process for the other frame components (Head Tube, Oblique Tube, Rear Fender, Front Fender, Battery Compartment Rear Baffle and Kickstand Mounting Bracket) are done in Vietnam. The parts are manufactured in Vietnam and welded to complete the frame. It takes approximately 3.5 manhours to complete the frame assembly. The assembled frame is then sent to China to be assembled with the remaining scooter components, all of China-origin. Main Assembly Line Process Flow Chart in Vietnam: Frame pressure bowl set - decorate upper and lower shells before installation Install the shock absorber frame labeling mounting foot support + disc brake adaptor Fix the left and right ambiance light foam on the frame + installation of disc brake seat Fitting rear fender fitting the hub motor fitting rear fork trim cover install the left and right ambiance light rubber plugs Fitting front wheel assembly pass through the main control cable and rear brake cable rear brake line fixed Install the battery compartment cover plate assembly foldable stand wearing the rear brake line assembly the main control cable Harness plug-in packing waterproof foam resistance test waterproof dispensing Fixed controller- fixed built-in power charger securing battery assembly install the AC charging base Fitting the rear wing + labeling assembly DC charging base install the left and right rear side edges Forehead assembly- fixed forehead Commissioning brake detection fitting handle assembly- ride test High pressure resistance test folding torque test hook test AC charging port test restoring factory settings Handling, transporting, and conveying production components Processing, assembling, packaging, etc. of components Processing and inspection simultaneously within the given time Store production components in designated storage areas (material preparation) Processing and handling simultaneously within the given time. Final Scooter Assembly in China - The Key Components of the scooter are fitted to the frame in China: AC Charging Port Assembly DC Charging Port Assembly Class 9 Hazard Label Assembly Front Wheel Suspension Assembly Front Wheel Assembly Packaging Assembly Rear Fender Assembly Carrying Handle Assembly Carton Marking Assembly Bare Chassis Assembly Frame Assembly Accessory Assembly Front Stem Assembly When determining the country of origin for purposes of applying current trade remedies under Section 301 {insert Section 301, Section 201, or Section 232, as appropriate} and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter 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). Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be able to know by an inspection of the marking on the imported goods the country of which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940). 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 integral parts of a new article, possessing new a names, characters and uses. Therefore, it is our opinion that the country of origin for the MAX G3 electric scooter will be Vietnam. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division