The country of origin of golf cart assemblies

N355050
November 18, 2025
OT:RR:NC:N2:206
CATEGORY: Origin Jing Zhang Mayer Brown LLP 1999 K St NW Washington, DC 20006 RE: The country of origin of golf cart assemblies Dear Jing Zhang: In your letter dated October 20, 2025, you requested a country of origin ruling on golf cart assemblies, which you filed on behalf of Vietnam Hengyu Electric Vehicle Co. Ltd. The products under consideration are golf cart assemblies, D5 Series 4-Seater Golf Cart Chassis Assembly (Chassis Assembly I) and D5 4-Seater Lifted Cart Chassis Assembly (Chassis Assembly II). The products are almost identical to each other except for minor differences in height and the shape of one frame subcomponent. You state that the chassis assemblies consist of 125 components, among which 76 are of Vietnamese origin, while the rest are mainly from China. The chassis frame is manufactured in Vietnam from steel plates, rectangular and round steel tubes, and round steel by cutting, bending, hole-making, and welding all subparts together. Protective layers are then applied to the chassis frame by electrodeposition and powder coating. After the frame is complete, numerous Vietnamese components, such as the middle bucket frame and injection molding parts that create the overall shape of the chassis assemblies, are installed. Then other subassemblies created in Vietnam from components of Chinese and Vietnamese origin are added. These subassemblies include front disc brake caliper, electromagnetic brake controller, DC converter, amplifier board, left/right front/rear seat bucket speakers, instrument panel, front/rear cowl, rear bumper, instrument panel storage box, and storage box. 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). In the present case the frame of the chassis assemblies is the character of the final product. The raw materials to create the frame are substantially transformed in Vietnam from steel plates, rectangular and round steel

tubes, and round steel into an identifiable article - the frame. Other minor components then lose their individual identities and become parts of the chassis assemblies in Vietnam. As a result, a substantial transformation occurs in Vietnam. Therefore, the country of origin of the Chassis Assembly I and Chassis Assembly II is 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 Liana Alvarez at [email protected].
Sincerely,
(for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division