The country of origin of a low-speed vehicle

N357185
January 8, 2026
OT:RR:NC:N2:201
CATEGORY: Origin Kevin Doucette C.H. Robinson International, Inc. 14701 Charlson Rd. Eden Prairie, MN 55347 RE: The country of origin of a low-speed vehicle Dear Mr. Doucette: In your letter dated December 18, 2025, you requested a country of origin ruling on behalf of your client, Lil Pick Up, Inc., located in Jurupa Valley, CA. The item under consideration has been identified as the Shuttlecross Golf F-4, a low-speed vehicle. The vehicle is equipped with a 9.7-inch waterproof vertical display, and seating for four (4) passengers, although the provided photos show seating for six (6). The Shuttlecross is equipped with the following: Powerful 48V AC Motor delivering 5.0 kW output Lithium Iron Phosphate Battery Pack for reliable, long-lasting energy Four-wheel disc brakes for superior stopping power Max speed of 40 km/h with seating for four passengers Large rear storage box for practical utility In your request you state that this product is not a Complete Knock-Down (CKD) or Semi-Knock-Down (SKD) operation, where the vehicle is shipped in parts for assembly elsewhere. You state that all major assembly steps and substantial transformation occur entirely in Vietnam. You provided photos and video documentation. You state that the frame and body of the vehicle are manufactured, built, and assembled entirely in Vietnam, with no frame-related or body subassemblies produced outside the country. Furthermore, major components used in the manufacturing of the vehicle are sourced from Vietnam, including: Frame Motor

Additional components such as chassis parts, suspension components, plastic body panels, and lighting components are also detailed in your supplied Bill of Material (BOM), which specifies the country of origin for each part. The vehicle is fully assembled in Vietnam, where the final substantial transformation occurs. Key production and assembly processes conducted at the Vietnam facility include: Chassis and frame assembly Motor installation Electrical harness and wiring installation Suspension, brake system, and drivetrain assembly Body panel and plastic component installation Final functional testing, calibration, and quality inspection All major manufacturing and assembly operations required to produce a completed vehicle are performed in Vietnam. 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). According to the information provided, the Shuttlecross F-4 all manufacturing and assembly process takes place in Vietnam. As outlined below, a series of detailed manufacturing operations are undertaken at this facility including: Metal fabrication Welding Coating Sub-assembly Integration, and Final testing The Shuttlecross F-4 undergoes a comprehensive manufacturing process that spans approximately 5.6 hours and involves the integration of 216 individual components in the following manufacturing phases: 1. Pipe Laser Cutting- Raw steel rods are precision-cut based on CAD designs. These form the structural frame components. 2. Tube bending- Custom bending operations shape the pipes into frame and support structures. 3. Hydraulic press machines. 4. Assemble and Weld Sub-Frames. 5. Frame alignment. 6. Fit Up and Weld Sub-Frames into Complete Frame. 7. Surface Treatment- Powder coating and painting for corrosion protection of all welded metal components. 8. Pre-assembly of Motor brackets, cooling systems, plastic hoods, and lighting. 9. Installation of plastic panels, wiring harness (manufactured in Vietnam), and major sub-systems. 10. Final assembly—mounting of Motor, body panels, suspension, and electronics. 11. Testing and Quality Control- Each vehicle is subjected to full functional testing, alignment, safety checks, and cosmetic inspection.

11. You contend that the assembly process involves skilled, labor-intensive operations requiring more than 5.6 hours to complete each Shuttlecross F-4. These activities significantly exceed basic ‘screwdriver’ assembly and constitute substantial transformation, resulting in the creation of a new and distinct article of commerce. We concur. It is the opinion of this office that, based on the information provided, the processes that take place in Vietnam substantially transform the individual components into complete low-speed vehicles. These processes are sufficiently complex and meaningful and result in a substantial transformation, such that the non-originating components losing their individual identities and become an integral part of new articles, possessing new names, characters and uses. Therefore, it is our opinion that the country of origin for the Shuttlecross F-4will 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division