Country of Origin Determination for Section 301 Tariff Purposes – Bicycle Assembled in China with Frame Made in Cambodia

N350528
July 10, 2025
OT:RR:NC:N2:201
CATEGORY: Origin Kerry Wang Braumiller Law Group, PLLC 5220 Spring Valley Road, Suite 200 Dallas, TX 75254 RE: Country of Origin Determination for Section 301 Tariff Purposes – Bicycle Assembled in China with Frame Made in Cambodia Dear Ms. Wang: In your letter dated June 23, 2025, you requested a country of origin ruling for purposes of applying Section 301 duties, on behalf of your client, Huffy Corporation (“Huffy”), located in Miamisburg, Ohio. The following ruling is based on the information submitted. The Rock Creek Mountain bicycle (Model 56301) is a complete bicycle that is exported from China to the United States. The production occurs in the following sequence: Raw steel tubing of Chinese origin is exported to Cambodia, where it undergoes cutting, bending, welding, shaping, heat treatment, and painting to produce a finished bicycle frame. The completed frame is then shipped to China, where it is assembled with various components (e.g., drivetrain, wheels, handlebars, seat), all of which are Chinese origin. The completed bicycle is exported to the United States. 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). CBP precedent recognizes that, in the case of bicycles, the frame imparts the essential character of the finished article. Notably: NY N345038 (Jan. 27, 2025) – The frame was deemed the “essence of the bicycle,” and origin was assigned to the country where the frame was made.

NY N329722 (Dec. 20, 2022) – Held that the frame sourced from Vietnam is the essence of the [bicycle], and the assembly operations of the various components in China do not result in a substantial transformation of the bicycle frames. Therefore, the country of origin of the [bicycle] is Vietnam. HQ H302358 (Jan. 23, 2020) – Found that a bicycle manufactured in Taiwan with its frame sourced from China, and the remaining components sourced from Taiwan, China, Japan, and the United States, was a product of China. CBP noted that the frame was the most essential component of the bicycle as it imparts the overall shape, size, and character of the product and that the other parts of the bicycle lose their separate identity once they are attached to the frame. In this case, the raw steel tubing of Chinese origin undergoes significant manufacturing in Cambodia. The processes — cutting, shaping, welding, heat-treating, and finishing — transform the steel 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 Chinese material. Although final assembly occurs in China using all Chinese components, the operations in China do not result in a substantial transformation. The frame gives the bike is overall shape, size, and character. The addition of components such as handlebars, wheels, and seats — though necessary — 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 Rock Creek Mountain bicycle (Model 56301) is Cambodia for purposes of applying trade remedies. Therefore, trade remedies under Section 301, as amended, from China will not apply. 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,
James Forkan Acting Director National Commodity Specialist Division