The country of origin of an electric bicycle (e-bike)

N356544 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 bicycle (e-bike) Dear Ms. Murrin: In your letter dated December 1, 2025, you requested a country of origin ruling on an e-bike, on behalf of Segway Inc. The item under consideration has been identified as a Segway e-bike, model TDM004Z. You have posed two manufacturing scenarios, the only difference between the two being the country where the frame is painted. You provided both diagrams and a comprehensive video showing the manufacturing and final assembly processes. In scenario 1, the following components of the frame are sourced from and are manufactured in Cambodia: Right and Left Chain stay Right and Left Seat stay Seat Tube Down Tube, and Head Tube The remaining frame components originate from China, some of which consist of: Brake Cable Threading Guide Bottom Bracket Fender Screw Nut Rack Screw Nut Water Bottle Screw Nut Cable Clip Chain stay Support Rod Welding Plate Chain stay Support Rod Right/Left Dropout Seat Tube Seat Tube Upper Reinforcement Plate Segway, in Cambodia, performs the following processes: Complete frame welding Grinding Polishing Heat treatment Correcting deformities (that may occur during welding) Heat treatment and Painting the frame The finished frame is sent to China where final assembly of the e-bike takes place. In both scenarios, the following manufacturing steps take place in Cambodia during the frame production stage. The raw material is: Cut Beveled Chamfered Deburred Bent (Chain stay and Seat stay) Shaped (Down tube) CNC Machined and turned Ground Polished Heat treated Welded Ribs are welded inside the down tube Scenario 2 is identical to Scenario 1 with the exception of the frame being painted in China. Using a welding machine, the head tube and down tube are welded together, forming the head tube assembly. The down tube, bottom bracket, and seat tube are welded to form the front triangle. The chain stays are welded to the bottom bracket. The seat stays are welded to the chain stays and seat tube. Finishing operations include reaming pre-drilled holes, drilling and tapping, inspection, and calibration. This is followed by the Post-Welding Processing, which includes: Mill the lower chain stay to shape its arc as required Heat the frame in a furnace to reduce hardness and enhance corrosion resistance Apply a solvent coating and bake the frame Remove surface dents using thorium supplementation. The frame is then sent to China. The remaining components of the e-bike are assembled to the frame in China, including the fork, seat post, saddle, handlebars, motor, battery, controller, throttle, torque sensor, brakes, electrical components, wire harness, wheels, and tires. 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). CBP has historically held that the frame is the part of the bicycle that imparts the character of the item and th at further assembly into a finished bicycle does not substantially transform the frame. (See N319181 (May 27, 2021), N344245 (December 20, 2024), N350306 (July 3, 2025) and H302358 (January 23, 2020)) In the Segway scenarios at issue, the key components of the frame are of Cambodia-origin. These include the down tube, seat tube, head tube, left and right chain stays, and left and right seat stays. Together these parts represent a majority of the total value of the frame components, and they define the frame’s structure and function. Manufacturing the frame is a complex process that results in a substantial transformation such that the country of origin of the frame is Cambodia. The assembly process in China into a complete e-bike is determined to be a finishing operation that does not define the character of the product. The origin of the frame determines the origin of the finished electric bike. Based on the foregoing analysis and consistent with CBP’s aforementioned rulings, it is the opinion of this office that the country-of-origin of the Segway e-bike, model TDM004Z, is 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division