OT:RR:NC:N2:201
Lisa Murrin
Expeditors Tradewin LLC
795 Jubilee Drive
Peabody, MA 01960
RE: The country of origin of an electric scooter
Dear Ms. Murrin:
This replaces Ruling Number, N356467, dated December 22, 2025, which contained a clerical error. We
inadvertently stated that the frame and electric scoter were assembled in Vietnam. Only the frame is
manufactured in Vietnam, the frame is sent to China where the rest of the electric scooter is completed. A
complete corrected ruling follows.
In your letter dated November 26, 2025, you requested a country-of-origin ruling on an electric scooter, on
behalf of your client Segway, Inc.
In your request, you state that the electric scooters frame is manufactured and assembled in Vietnam; then
sent to China for final scooter assembly. You express that the basic frame components are obtained through
the aluminum extrusion process. It then undergoes shaping/correction via CNC machining. The frame is then
inspected. You presented documents and a video/compact disc showing the production work done in
Vietnam. You provided a Bill of Material (BOM) showing the country of origin of all components and
materials used in the manufacturing process.
The MAX G3 electric scooter is a two-wheeled stand-up scooter. It is equipped with a:
2,000-watt motor
Maximum speed of 28 mph
Range of up to 50 miles
Battery capacity of 597 WH (watt-hours)
In your production video you show that raw aluminum alloy is extruded into a frame component in Vietnam.
It undergoes the following manufacturing processes:
CNC machining and inspection in Vietnam.
The manufacturing process for the other frame components (Head Tube, Oblique Tube, Rear Fender, Front
Fender, Battery Compartment Rear Baffle and Kickstand Mounting Bracket) are done in Vietnam. The parts
are manufactured in Vietnam and welded to complete the frame. It takes approximately 3.5 manhours to
complete the frame assembly. The assembled frame is then sent to China to be assembled with the remaining
scooter components, all of China-origin.
Main Assembly Line Process Flow Chart in Vietnam:
Frame pressure bowl set - decorate upper and lower shells before installation
Install the shock absorber frame labeling mounting foot support + disc brake adaptor
Fix the left and right ambiance light foam on the frame + installation of disc brake seat
Fitting rear fender fitting the hub motor fitting rear fork trim cover install the left and right ambiance
light rubber plugs
Fitting front wheel assembly pass through the main control cable and rear brake cable rear brake line
fixed
Install the battery compartment cover plate assembly foldable stand wearing the rear brake line
assembly the main control cable
Harness plug-in packing waterproof foam resistance test waterproof dispensing
Fixed controller-
fixed built-in power charger securing battery assembly install the AC charging base
Fitting the rear wing + labeling assembly DC charging base install the left and right rear side edges
Forehead assembly-fixed forehead
Commissioning brake detection fitting handle assembly-ride test
High pressure resistance test folding torque test hook test
AC charging port test restoring factory settings
Handling, transporting, and conveying production components
Processing, assembling, packaging, etc. of components
Processing and inspection simultaneously within the given time
Store production components in designated storage areas (material preparation)
Processing and handling simultaneously within the given time.
Final Scooter Assembly in China - The Key Components of the scooter are fitted to the frame in China:
AC Charging Port Assembly
DC Charging Port Assembly
Class 9 Hazard Label Assembly
Front Wheel Suspension Assembly
Front Wheel Assembly
Packaging Assembly
Rear Fender Assembly
Carrying Handle Assembly
Carton Marking Assembly
Bare Chassis Assembly
Frame Assembly
Accessory Assembly
Front Stem Assembly
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).
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. Friedlander & Co., 27 C.C.P.A. 297, 302 (1940).
These processes are sufficiently complex and meaningful and result in a substantial transformation, such that
the non-originating components lose their individual identities and become integral parts of a new article,
possessing a new name, character and use. Therefore, it is our opinion that the country of origin for the MAX
G3 electric scooter 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 [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division