RE: The country of origin of a Segway off-road vehicle

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N363894 August 19, 2026 OT:RR:NC:N2:201 CATEGORY: Origin Ms. Lisa Murrin Expeditors Tradewin LLC 795 Jubilee Drive Peabody, MA 01960 RE: The country of origin of a Segway off-road vehicle Dear Ms. Murrin: In your letter dated July 31, 2026, you requested, on behalf of your client, Segway Powersports, Inc., located in McKinney, TX, a country of origin ruling on an off-road vehicle assembled in Thailand. The item under consideration is identified as the Segway off-road vehicle, model # UT10050F41USA7102. The submitted request identified over 600 parts that are shipped from China to Thailand and assembled into the finished vehicle. The main assembly line processes are highlighted below. Install the frame on the main line. Stamp and fit the frame with nameplate and traceability coding. Install the front axle, rear stabilizer bar, panel, and heat shield. Pre-assemble the steering gear (subassembly). Program ECU (engine control unit)/T-Box. Install the floor panel and pre-install water pipes. Pre-assemble exhaust elbow (subassembly) and install. Pre-install the engine mounting brackets, and install the engine. Install the drive shaft, air filter, throttle body, air ducts and engine exhaust pipe. Assemble the left and right-side drivetrain and suspension components, including constant-velocity shafts, control arms, stabilizer bar joints, hub assemblies, brakes, shocks, and steering tie rods. Assemble and install fuel tank, seat brackets, and radiator. Install the electrical systems, including wiring harnesses, instrument panel, control modules, rectifier, and relays. Install the interior and control components, including seats, pedals, steering column, and shift mechanism. Install the vehicle exterior parts/accessories, including bumper, lighting, panels, and covers. Complete final connections (brake lines, throttle, wiring, and piping), and fill fluids. Pre-install steering wheel. Vehicle undergoes performance testing.
Assemble and install cargo box and remaining accessories. Documentation, as provided, indicates that the Segway will go through ten (10) workstations. The entire assembly process takes eleven (11) workers approximately 15.55 hours per vehicle. 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). The substantial transformation test is fact-specific and applied on a case-by-case basis depending on the totality of factors. The primary focus of the substantial transformation test is whether the work or material added to an article in another country changed the character or use of the article. A change in the name of materials added to an article, without more, will rarely support the interpretation that the processing in question substantially transformed those materials. In determining whether the combining of parts or materials constitutes a substantial transformation, the determinative issue is the extent of operations performed and whether the parts lose their identity and become an integral part of the new article. Belcrest Linens v. United States, 573 F. Supp. 1149 (Ct. Int’l Trade 1983), aff’d, 741 F.2d 1368 (Fed. Cir. 1984). The country of origin of the item’s components, extent of the processing that occurs within a country, and whether such processing renders a product with a new name, character, and use are primary considerations in such cases. In binding ruling N320280 (July 22, 2021), CBP determined the country of origin of a similar all-terrain vehicle (ATV) assembled in Thailand from Chinese components. As described in this ruling, the ATV is comprised of 1,375 component parts, and went through 22 “main,” 14 “sub,” and 3 “inspection” stations during the assembly processes. Some of the assembly processes include: Assembly of engine and front and rear axles. Assembly of rear suspension, which includes installation of left and right rocker arm subassemblies, the rear sway bar, and mounting brackets for shock absorbers and brake calipers. Assembly of main cable and middle functional parts of vehicle body, which includes the radiator and cooling system, fuel tank, voltage regulator, steering wheel and system related components, Continuous Variable Transmission (CVT), and air filters. Installation of dashboard, upper panel, and headlight sub-assembly. The fabrication of the vehicle frame, which included welding and electrophoretic painting in China, was considered its own subassembly. CBP held that the country of origin of the ATV was Thailand because the assembly process is sufficiently complex to constitute a substantial transformation and results in an article with a new name, character, and use. In many cited rulings CBP did note that the “assembly of components is necessary for the ATV to function, and that the assembly results in a substantial transformation.” The assembly process of the Segway is similar as described above. You state that the following key assembly steps take place in Thailand: Assembly of the engine, axle, and rear stabilizer bar. Assembly of the radiator, fuel tank, steering wheel, air filter, drive shaft, and exhaust. Installation of electrical systems, including instrument panel, control modules, and wiring harnesses. Installation of interior and exterior components, including seats, pedals, bumper, lighting, and panels.
Numerous subassemblies are assembled in Thailand, along with the assembly of hundreds of parts. Some of these subassemblies include the steering gear, exhaust elbow, seat brackets, radiator, and brake pedal. The assembly operations performed in Thailand involve the integration of the engine, drivetrain, suspension, steering, braking, electrical, and other systems necessary to produce a functioning off-road vehicle. Similar to the assembly operations described in N320280, the processing performed in Thailand is sufficiently complex to result in a substantial transformation of the imported components into a new and distinct article with a new name, character, and use. Based on the foregoing, it is the opinion of this office that the country of origin of the Segway, model #UT10050F41USA7102, is 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) James P. Forkan Director National Commodity Specialist Division