CBP Finds U.S. is Country of Origin for Vantage Electric Vehicles
CBP issued a final determination concerning the country of origin of Vantage Vehicle electric trucks and vans. CBP has determined that the U.S. is the country of origin of the low speed electric trucks (models EVX1000 and EVR1000) and electric vans (models EVC1000 and EVP1000) for purposes of U.S. government procurement.
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The final determination was issued at the request of Vantage Vehicle International.
(CBP issues country of origin advisory rulings and final determinations on whether an article is or would be a product of a designated country or instrumentality for the purpose of granting waivers of certain ‘‘Buy American’’ restrictions in U.S. law or practice for products offered for sale to the U.S. government.)
Vehicles Assembled from Foreign and U.S. Parts
Vantage imports "rolling chassis," also know as gliders, from China into the U.S. and converts them into low speed electric trucks and vans. Vantage then assembles the gliders with other components including motors, controllers, chargers, batteries, instrument clusters, converters, wire harnesses, battery boxes, heater cores, and miscellaneous items such as fasteners and wires
Each vehicle assembled in the U.S. has about 67 components and assemblies and 146 miscellaneous items such as bolts, nuts, screws, fasteners and wires. All of the components and miscellaneous items are of U.S.-origin, except for the charger which is from Canada. Over 71 percent of the manufacturing cost of the vehicles is attributed to U.S. components and labor, about 26 percent to the Chinese glider, and about 2 percent to the Canadian charger.
CBP Says Vehicles of U.S. as Substantial Transformation Occurs There
CBP found the assembly of the imported parts together with the U.S.-made components was necessary to the operation of the finished product. None of the imported parts, on their own, can operate as an electric vehicle but must be assembled with other necessary components, such as batteries, motors, instrument clusters, and wiring assemblies, which are all of U.S. origin. Moreover, given the complexity and duration of the U.S. manufacturing process, we consider those operations to be more than mere assembly.
Therefore, CBP finds that the country of origin of the vehicles is the U.S. for government procurement purposes.
Any Party-at-Interest May Request Judicial Review by Jan. 7
CBP said any party-at-interest, as defined in 19 CFR 177.22(d), may seek judicial review of a final determination by Jan. 7. In addition, under 19 CFR 177.31, any party-at-interest other than the party which requested this final determination may request that CBP reexamine the matter anew and issue a new final determination.
CBP contact -Heather Pinnock (202) 325-0034
(FR Pub 12/07/12,HQ H229157)