CLA-2-87:OT:RR:NC:N2:206
Kerry Wang
Braumiller Law Group PLLC
5220 Spring Valley Road, Suite 200
Dallas, TX 92691-5939
RE: The tariff classification and country of origin of a body panel and chassis assembly
Dear Ms. Wang:
In your letter dated December 30, 2025, you requested a tariff classification and country of origin
determination ruling, which you filed on behalf of your client, Denago EV Corporation.
The article under consideration is a body panel and chassis assembly (BP&C) for the Nomad XL low-speed
electric vehicle. You state that the Nomad XL is designed to be configurable as either a golf cart or a
low-speed vehicle. When imported into the United States, the BP&C consists of a fully formed, unitized
vehicle structure that constitutes the foundational platform of the Nomad XL. The BP&C integrates both the
primary structural chassis and the exterior body architecture of the vehicle and is designed exclusively for use
as a Nomad XL motor vehicle.
You state that at the time of importation, the BP&C includes a rigid, welded steel chassis frame,
manufactured from cut, formed, and welded steel tubing and T4/T6 treatment stamped steel components,
which provides the load-bearing structure of the vehicle. Additionally, it features a molded and assembled
exterior body panels, suspensions, steering knuckles, shock absorbers and mechanical linkages, structural
points for future electrical and powertrain installation, and includes an integrated motor controller. The
BP&C will does not contain the electric motor, battery pack, powertrain electronics, steering wheel, brakes,
road wheels, roof, windscreens, or accessory equipment.
The BP&C is manufactured in Vietnam through a vertically integrated production process that begins with
raw steel and plastic inputs and results in a fully assembled, non-powered vehicle structure. Manufacturing
commences with the cutting and forming of Vietnamese-origin steel into steel tubing and stamped steel
brackets using computer numerical control (CNC) equipment. These formed components are placed into
dedicated welding fixtures that hold the parts during joining. The components are then joined using metal
inert gas (MIG) welding, a semi-automated arcwelding process where a continuously fed wire electrode is
melted and fused with the base metal under a shielding gas. This process results in a rigid, unitized chassis
frame of the vehicle platform.
You state that while the majority of the BP&C components are produced in Vietnam, certain exterior plastic
body parts are manufactured in China and imported into Vietnam for integration into the assembly. These
Chinese-origin parts consist of plastic exterior panels, interior trim parts, and battery housing elements,
including covers, baseboards, floor mats, and rear support plates.
Following welding, individual frame components are assembled into chassis subassemblies, which are then
joined using bolted connections to form the complete chassis frame. Once assembled, the frame undergoes
post-weld stress-relief and surface preparation processes to enhance structural integrity and long-term
durability. The frame is then treated with anti-corrosion coatings, such as e-coating or equivalent protective
finishes, to protect against environmental exposure. In parallel with chassis fabrication, the exterior body
components are produced in Vietnam using large tonnage injection molding machines. These machines mold
thermoplastic materials into finished body parts, including the front cowl, dashboard shell, side panels,
under-seat tub, and rear body module. After molding, the components are trimmed, inspected, and prepared
for assembly.
Final assembly of BP&C in Vietnam integrates these molded body components with the welded chassis using
dedicated location jigs that ensure precise fit and alignment. The facility in Vietnam also completes the
installation of non-powertrain mechanical and structural subsystems, including the front suspension
assembly, steering knuckles, shock absorbers, and associated mechanical linkages. In addition, base electrical
interface hardware is installed, such as wiring harness routing mounts, controller mounting brackets, and
switch housings, which establish the physical infrastructure for later electrical integration. These
manufacturing and assembly operations culminate into a finished platform that incorporates the full welded
frame, structural body shell, seating tub, suspension system, and dashboard components. The BP&C is
intentionally produced without any powertrain, battery system, motor, controller, or high-voltage wiring,
reserving these components for final subsequent installation in the United States.
In your letter, you suggested classification of the BP&C in subheading 8703.10.5060, Harmonized Tariff
Schedule of the United States (HTSUS), as an incomplete motor vehicle other than a golf cart. We disagree.
Based on the information provided, the BP&C is designed to be configurable as either a golf cart or a
low-speed vehicle. You state that as imported, the BP&C assembly consists of a fully formed, unitized
vehicle structure that constitutes the foundational platform of the Nomad XL. Although we concur that from
an examination of the item as imported it is the basic structure of the vehicle, but it is our opinion the BP&C
assembly does not possess enough essential components to classify the chassis assembly as either an
“unfinished” or “incomplete” vehicle. General Rule of Interpretation 2(a) states that:
Any reference in a heading to an article shall be taken to include a reference to that article incomplete
or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character
of the complete or finished article. It shall also include a reference to that article complete or finished
(or falling to be classified as complete or finished by virtue of this rule), entered unassembled or
disassembled.
The Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System, which
represent the official interpretation of the tariff at the international level, facilitate classification under the
HTSUS by offering guidance in understanding the scope of the headings and the GRIs. The ENs to Chapter
87 states:
An incomplete or unfinished vehicle, whether or not assembled, is classified as the corresponding
complete or finished vehicle provided it has the essential character of the latter (see General Interpretative
Rule 2 (a)), as for example:
(A) A motor vehicle, not yet fitted with the wheels or tyres and battery.
(B) A motor vehicle not equipped with its engine or with its interior fittings.
You state that the BP&C integrates both the primary structural chassis and the exterior body architecture of
the vehicle and is dedicated exclusively for use as a Nomad XL motor vehicle. While this may be true, it is
still missing electric motor, battery pack or energy storage system, powertrain electronics, brakes and wheels,
and roof, windscreen, or accessory equipment.
It is the opinion of this office that there is not enough incorporated into the BP&C to raise it to the level of an
“incomplete” vehicle. As such, it would be excluded from classification in 8703.
You also note that the BP&C is not an article of heading 8708, HTSUS, which provides for parts of vehicles,
because it is the foundational vehicle structure upon which all remaining components are installed. It is the
vehicle platform, not a subordinate component thereof. We agree.
The applicable subheading for the body panel and chassis assembly for the Nomad XL low-speed electric
vehicle will be 8707.10.0020, HTSUS, which provides for “Bodies (including cabs), for the motor vehicles of
headings 8701 to 8705: For vehicles of heading 8703: For passenger automobiles.” The general rate of duty
will be 2.5 percent, ad valorem.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience
and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided
at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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 (“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).
In the present case, the frame of the BP&C is produced in Vietnam. Furthermore, the Chinese plastic
components are made into sub-assemblies in Vietnam and the final assembly occurs in Vietnam. As a result,
it is the opinion of this office that the country of origin of the BP&C for the Nomad XL low-speed electric
vehicle will be Vietnam for applying current trade remedies under Section 301 and additional duties.
In your letter you also inquired whether the BP&C were subject to Vehicle Identification Number (“VIN”)
requirements at the time of importation. Please note that the issue is outside of CBP’s purview. VIN
requirements questions may be directed to the National Highway Traffic Safety Administration (NHTSA) at
888-327-4236 or by visiting https://vpic.nhtsa.dot.gov/
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 [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division