OT:RR:NC:N2:201
David Wei
Ride Aventon Inc.
3040 Saturn St. Ste 202
Brea, CA 92821
RE: Country of origin of electric bicycles
Dear Mr. Wei:
In your letter dated January 8, 2026, you requested a country of origin ruling on your Aventon electric
bicycles (“e-bikes”), which are assembled in China using frames manufactured in Thailand.
The items under consideration have been identified as three (3) models of Aventon e-bikes, “Aventure,”
“Level,” and “Pace,” which are assembled in China using components manufactured in China, Indonesia and
Vietnam. The frame of the e-bikes will be wholly produced in Thailand from raw materials sourced from
China and Thailand. The frame production stage in Thailand will consist of the following manufacturing
steps.
Tube Cutting
Tube Taper
Tube Forming
Tube Shearing
Drilling
Welding Cable Guides
Cleaning
Tack Welding
Triangle Alignment Check
T4 Heat Treatment
Frame Alignment Check
T6 Heat Treatment
Machining
Surface Polishing
Painting
Sticker Placement
Packing
The completed frame is then shipped to China, where it is assembled with the remaining e-bike components.
Once the frame arrives in China, the final e-bike is then assembled by installing the following components
together:
Headset
Hanger
Set clamp
Fenders
Rear rack
Cable assembly
Controller
Lights
Crank set
Mounts
Kickstand
Brake
Handlebar
Wheels
Cables
Seat to the e-bike frame and attaching various subassemblies onto the frame
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).
Additionally, Section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that unless
excepted, every article of foreign origin imported into the United States shall be marked in a conspicuous
place as legibly, indelibly, and permanently as the nature of the article (or its container) will permit, in such a
manner as to indicate to the ultimate purchaser in the United States, the English name of the country of origin
of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate purchaser should be
able to know by an inspection of the marking on the imported goods the country of which the goods is the
product. The evident purpose is to mark the goods so that at the time of purchase the ultimate purchaser may,
by knowing where the goods were produced, be able to buy or refuse to buy them, if such marking should
influence his will.” See United States v. Friedlaender & Co., 27 C.C.P.A. 297, 302 (1940).
Part 134 of the U.S. Customs and Border Protection (“CBP”) Regulations (19 CFR 134) implements the
country-of-origin marking requirements and exceptions of 19 U.S.C. 1304. Section 134.1(b), CBP
Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of manufacture, production, or
growth of any article of foreign origin entering the United States. Further work or material added to an article
in another country must effect a substantial transformation in order to render such other country the “country
of origin” within the meaning of the marking laws and regulations.
In this case, the raw tubing of Chinese and Thailand origin undergoes significant manufacturing in Thailand.
These processes transform the tubing into a finished bicycle frame with distinct characteristics and function.
CBP has found that this level of fabrication constitutes a substantial transformation of the raw materials into a
distinct product.
Although final assembly occurs in China, these operations do not result in a substantial transformation of the
frame. The frame gives the bike is overall shape, size, and character. The addition of components such as
handlebars, wheels, and seats do not change the nature or use of the product already defined by the frame.
Based on the information provided and applicable CBP precedent, the country of origin of the Aventon
“Adventure”, “Level”, and “Pace” e-bike is Thailand for purposes of applying trade remedies and for
marking. Therefore, trade remedies under Section 301, as amended, from China will not apply.
In this instance, we find that the frame imparts the character to the noted models of Aventon e-bikes. The
frame is the costliest component and imparts to the bicycle its overall shape, size, and character. Accordingly,
because the material that imparts the character to the good, the frame is of Thailand origin, the country of
origin of the entire imported good is Thailand for marking purposes and the bicycle needs to be marked as
“Made in Thailand.”
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 [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division