The country of origin of golf cars chassis assemblies

N356958 January 7, 2026 OT:RR:NC:N2:206 CATEGORY: Origin Jing Zhang Mayer Brown LLP 1999 K Street NW Washington, DC 20006 RE: The country of origin of golf cars chassis assemblies Dear Ms. Zhang: In your letter dated December 11, 2025, you requested a country of origin ruling on the chassis assemblies, which you filed on behalf of Vietnam Hengyu Electric Vehicle Co. Ltd. The articles under consideration are D5 Series Chassis Assemblies, which are golf cart chassis assemblies for the 6-seater golf carts with six forward-facing seats, 6-seater golf carts where the last row of 2 seats is backward-facing, and 4-seater golf carts with two forward-facing seats and two backward-facing seats. Each D5 series chassis assembly model has a standard version and a lifted version, which are virtually identical to each other except for minor differences in chassis height and the specifications of a few (less than three) components. You state that the D5 chassis assemblies consist of 94 to 126 components, the majority of which are of Vietnamese origin. Specifically, in Vietnam raw steel, i.e., steel plates, steel tubes (rectangular and round), and round steel, are first made into various chassis frame subparts in sophisticated, precise shapes by cutting, bending, stamping and hole-making. Then various frame subparts are made into front-end, frame body, and rear-end subassemblies for the chassis frame by complex welding operations. The complete chassis frame is then created from the front-end, frame body, and rear-end subassemblies by complex welding operations. Protective layers (e.g., paint and powder) are applied to the chassis frame by electrodeposition and powder coating through a 19-step process. The coated chassis frame is then inspected before going into the next production stage, which is combining with numerous Vietnamese components, including the middle bucket frame and injection molding parts, and Chinese components to form the finished chassis assemblies. During this process, various subassemblies are created in Vietnam for each chassis assembly, including the instrument panel subassembly, the front cowl subassembly, the rear cowl subassembly, the L front seat bucket speaker subassembly, the R front seat bucket speaker subassembly, the amplifier board subassembly, the instrument panel storage box subassembly, and the left/right front support subassembly. 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 appears that this office already ruled on a similar scenario in N355050, dated November 18, 2025. In that ruling we stated, “In the present case the frame of the chassis assemblies is the character of the final product. The raw materials to create the frame are substantially transformed in Vietnam from steel plates, rectangular and round steel tubes, and round steel into an identifiable article - the frame. Other minor components then lose their individual identities and become parts of the chassis assemblies in Vietnam. As a result, a substantial transformation occurs in Vietnam.” Similarly in this case, a substantial transformation occurs in Vietnam, and the Chinese components lose their individual identities and become parts of the chassis assemblies. Therefore, the country of origin for the D5 Series Chassis Assemblies 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 Liana Alvarez at liana.alvarez@cbp.dhs.gov. Sincerely, (for) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division