RE: The country of origin of a 2026 BMW X5 assembled in Spartanburg, SC

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 N365630 October 8, 2026 OT:RR:NC:N2:201 CATEGORY: Origin Ms. Tracy LePire 3770 River Loop Drive Biloxi, MS 39540 RE: The country of origin of a 2026 BMW X5 assembled in Spartanburg, SC Dear Ms. LePire: In your letter dated October 1, 2026, you requested a country of origin ruling on a 2026 BMW X5 Multipurpose Passenger Vehicle. The item under consideration has been identified as a 2026 BMW X5 Multipurpose Passenger Vehicle, VIN 5UX33EU02T94XXXXX, which is equipped with an 8-cylinder, 4,400 Cubic Centimeter (CC) gas-powered spark-ignition internal combustion engine. You state that vehicle was built and assembled at BMW's Spartanburg Facility, in Greer, South Carolina, that the vehicle has not increased in value nor was improved in condition, and was a personal purchase bought through BMW's Overseas U.S. Military Sales Program Office located in Kaiserslautern, German. 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). An examination of the supplied VIN has substantiated your claim that this vehicle is a Product of the United States, which is being returned after purchased through an Overseas U.S. Military Sales Program. The Country-of-Origin of the subject vehicle is the United States, and would be eligible for importation back to the United States under 9801.00.1065, Harmonized Tariff Schedule of the United States, which provides for, “Products of the United States when returned after having been exported, or any other products when returned within 3 years after having been exported, without having been advanced in value or improved in condition by any process of manufacture or other means while abroad: Other: Articles provided for in chapter 87: Articles provided for in heading 8703.” 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