The country of origin of bicycle frames manufactured in Canada

N362148 June 23, 2026 OT:RR:NC:N2:201 CATEGORY: Origin Mr. Mark Beaver Tamarack Cycles 5274 Russell Street Halifax, Nova Scotia RE: The country of origin of bicycle frames manufactured in Canada Dear Mr. Beaver: In your letter dated June 8, 2026, you requested a country of origin ruling on bicycle frames manufactured in Canada. The item under consideration has been identified as custom, handmade bicycle frames. You state that each bicycle that you make is individually handcrafted for the person who ordered it. You claim that no two frames are identical. You provided a video link showing a current frame in production and photos of the production steps. You indicate that your bicycle frames start as steel raw material. Steel tubing is sourced from distributors, some in USA, some in England. Bicycle tubing may be made in the United States, England, Italy, or Taiwan. You state that the various fittings needed to create the bicycle frame are similarly sourced from the same distributors. These fittings may consist of: Lugs- the "corners" of the frame. Dropouts- the fittings where the wheels are clamped. Fork crowns- the top of the front fork. Bottom brackets- where the bicycle cranks are attached. There are various other small fittings as well. These components are mostly made in Taiwan, England, Italy, or the USA. You state that your frame designs are crafted on computer software and transferred to a full scale drafting drawing. The tubes are then milled on a lathe to the correct lengths and angles. Taking the dimensions from the drawing, the individual pieces are brazed together by you using oxyacetylene brazing using a precision jig and using hand tools. 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). With the facts and documentation presented, it is the opinion of this office that the bicycle frame’s raw components and subassemblies will be substantially transformed by you during the manufacturing process in Canada. Thus, the country of origin of the complete bicycle frame, and completed bicycle using said frame for marking purposes will be Canada. As the country of origin of the subject item is Canada, the Section 301 Trade Remedy duties are not applicable, and the bicycle frame may be marked “Made in Canada.” 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