RE: The country of origin of an electric scooter

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 N364674 September 10, 2026 OT:RR:NC:N2:201 CATEGORY: Origin Gena Haddock Expeditors Tradewin 795 Jubilee Dr. Peabody, MA 01960 RE: The country of origin of an electric scooter Dear Ms. Haddock: In your letter dated August 27, 2026, you requested a country of origin ruling on an electric scooter, on behalf of your client Segway, Inc. The article under consideration is the Segway E2 Plus II electric scooter. The scooter consists of a steel frame to which various components are assembled, including a battery pack and battery box, an electric motor with integrated rear wheel, front wheel, controller, wiring harness, steering assembly, and front fork assembly. Your request presents two manufacturing scenarios for consideration. Under both scenarios, the scooter frame is manufactured in Vietnam from SPCC high-strength steel sheet and tubing sourced from Vietnam. With the exception of a drum brake pin sourced from China, the individual components comprising the frame are manufactured in Vietnam from steel sheet and tubing. In Vietnam, the steel sheet is first blanked using laser cutting equipment. The resulting blanks undergo various stamping, pressing, forming, machining, and tapping operations to manufacture the individual components of the scooter frame. These components include the left and right frame stampings, frame reinforcement plate, frame connecting plate, frame front support, fender mounting plate, kickstand fixing plate, name plate bracket and other components. The frame head tube is manufactured from tubing by laser cutting and computer numerical control (CNC) machining. After fabrication of the individual components, the components are transferred to the welding operation, where they are positioned in dedicated fixtures and permanently joined by robotic gas-shielded welding and other welding operations to form the completed scooter frame. Following welding, the frame undergoes finishing operations that include the removal of weld spatter, grinding, and smoothing of weld seams, correction of surface imperfections, alignment, and dimensional and structural inspection. You also provided video recordings depicting the manufacturing operations performed in Vietnam. The videos show the processing of steel material into the individual frame components and the subsequent welding and assembly operations used to manufacture the completed scooter frame.
Under Scenario 1, the completed frame undergoes electrodeposition coating (e-coating) in Vietnam before being exported to China. In China, the battery pack, battery box, electric motor with integrated rear wheel, front wheel, controller, wiring harness, steering assembly, front fork assembly, and other components are assembled to the Vietnamese-manufactured frame. The final assembly operations primarily consist of standard mechanical fastening and press-fit operations and take approximately 1.5 hours to complete. Under Scenario 2, the manufacturing and welding operations used to produce the completed frame are likewise performed in Vietnam. However, the completed frame is exported to China without undergoing e-coating. In China, the frame is e-coated before the remaining components are assembled to the frame in the same manner described above. 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 this case, we find that the manufacturing operations performed in Vietnam substantially transform the steel sheet and tubing into a new and different article of commerce. When received in Vietnam, the steel sheet and tubing are raw materials that do not possess the identity, character, or dedicated use of a scooter frame. Through the cutting, stamping, pressing, forming, machining, tapping, welding, finishing, alignment, and inspection operations performed in Vietnam, these materials are transformed into discrete frame components and subsequently into a completed scooter frame. Furthermore, we find that the subsequent operations performed in China do not substantially transform the Vietnamese-manufactured frame. The frame provides the fundamental structure of the finished scooter and serves as the platform to which the remaining components are attached. Although these components are necessary for the operation of the finished scooter, the Chinese assembly operations do not result in a new and different article of commerce. Accordingly, based on the totality of the circumstances, we find that the country of origin of the Segway E2 Plus II electric scooter is Vietnam under both Scenario 1 and Scenario 2. 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