The country of origin of a Low-Speed Vehicle (LSV)

N360705 April 24, 2026 OT:RR:NC:N2:201 CATEGORY: Origin Adam Klaser C.H. Robinson Worldwide, Inc. 26555 Evergreen Rd Southfield, MI 48076 RE: The country of origin of a Low-Speed Vehicle (LSV) Dear Mr. Klaser: In your letter dated April 14, 2026, you requested a country of origin ruling on behalf of your client, Golden Wing Industry, Inc., located in Riverside, CA. You requested a country of origin ruling for LSVs manufactured in Vietnam. You state that the request is to confirm Vietnamese origin for the purpose of confirming that Section 301, and Section 122 tariffs on Chinese origin products are not applicable. You presented documents, slides and videos showing the production work done in Vietnam. The product at issue is a LSV identified as the AXIOS E-ShuttleCross. The AXIOS E-ShuttleCross is an electric LSV equipped with: 48 Volt AC induction motor 12.5kW of peak power Electronic transmission Double A-arm independent suspension Max carrying capacity 300kg (661 lbs) Maximum speed 40 km/h (24.8 mph) The AXIOS E-ShuttleCross will be produced in Vietnam using imported Chinese and locally sourced Vietnamese raw materials, but all the production steps listed below will take place in Vietnam. You state that the AXIOS E-ShuttleCross undergoes a comprehensive manufacturing process that spans approximately 1.8 hours and involves the integration of 341 individual components. The production process for the AXIOS E-ShuttleCross is as follows: Pipe Laser Cutting Tube Bending Welding Hydraulic Pressing Assembly and Welding of Sub-Frames Frame Alignment Welding Sub-Frame to Main Frame Surface Treatment Pre-assembly of Motor brackets, cooling systems, plastic hoods, and lighting Installation of plastic panels, wiring harness (manufactured in Vietnam), and major sub-systems Final assembly—mounting of Motor, body panels, suspension, and electronics Testing and Quality Control You state that, upon completion, each vehicle is subjected to full functional testing, alignment, safety checks, and cosmetic inspection. When determining the country of origin for purposes of applying current trade remedies under Section 301 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). It is the opinion of this office that, based on the information provided, the processes that take place in Vietnam substantially transform the individual components sourced from China into complete LSVs. These processes are sufficiently complex and meaningful and result in a substantial transformation, such that the non-originating components losing 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 AXIOS ShuttleCross 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) James P. Forkan Director National Commodity Specialist Division