CBP Proposes to Change Rulings on E-Scooters, Shrimp Products

The following proposed revocations or modifications of U.S. Customs and Border Protection rulings are included in the Sept. 17, 2025, Customs Bulletin and Decisions. Comments on these proposed changes are due by Oct. 17.

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E-Scooters

CBP is proposing to modify ruling NY N344694 to hold that the country of origin of certain e-scooters for purposes of applying Section 301 tariffs is Taiwan instead of China.

The items at issue are solar and regenerative braking-powered seated e-scooters. They are primarily used as a personal conveyance by adults to commute to work or other activities of up to a dozen miles a day, primarily in urban or other locations with bike lanes. The e-scooter’s inner frame, stem, suspension, brakes, seating, and lights are all sourced from vendors in Taiwan; the battery is sourced from Germany; and the wheel hub motors, tires, tubes, throttles, grips, end caps, display, wiring harness, horn, on-board charger, solar panels, and maximum power point tracking system are all manufactured in China.

CBP previously determined that the solar panels impart the character of the e-scooters because they not only provide power but also are integral parts of the frame body. CBP also held that the culmination of production processes performed in Taiwan to the Chinese solar panel and inner Taiwanese frame did not substantially transform the solar panels.

However, citing additional evidence provided by the petitioner, CBP now finds that the solar panels are not structurally part of the frame and do not provide the primary power source. CBP therefore proposes to hold that the country of origin of the e-scooters is Taiwan because that is place of manufacture of the frame, which imparts the essence of the e-scooters.

Shrimp Products

CBP is proposing to reclassify shrimp spring rolls and breaded shrimp products as stuffed pasta under HTSUS 1902.20.00 (6.4 percent duty) rather than as preserved shrimp under HTSUS 1605.20.1030 (duty-free) or 1605.21.0500 (5 percent duty). Rulings NY N265988 and NY L86382 would be revoked to reflect this change.

The items at issue are (1) tortilla seafood spring rolls, which consist of a dough jacket stuffed with shrimp, vegetables, and seasonings that is rolled in tortilla chip crumbs and par-fried, and (2) three different preparations of headless, peeled, deveined shrimp with tail on that are seasoned, wrapped in pastry paper, and par-fried (the coatings on these shrimp total 50-60 percent of the product weight).

CBP states that because the outer shells of these products consist of a jacket made of wheat flour and water they are classifiable as stuffed pasta of heading 1902. As a result, Note 2 to Chapter 16 excludes them from classification in Chapter 16.