Recent CBP NY Rulings
The following are short summaries of recent CBP NY rulings issued by the agency's National Commodity Specialist Division in New York:
N341115: The country of origin of extension cords
| Origin: Thailand |
| Item: Indoor/outdoor extension cords. Each item comprises a length of insulated conductor with a plug at one end and an illuminated receptacle at the other. The manufacturing process for both cables is substantially similar and occurs in Thailand through the following steps. Copper wire of Thai origin is twisted, pulled, and insulated via an extrusion process. The electrical plug and receptacle are then assembled and added to each end of the cable. The parts used to assemble the plug and receptacle are sourced from China. The finished cords are then retail packaged for shipment to the United States. |
| Reason: The Thai-origin copper wire imparts the character of the finished articles. Further, the addition of the Chinese connectors does not substantially transform the insulated conductor into a new and different article of commerce with a name, character, and use distinct from the individual components. |
| Ruling Date: July 18, 2024 |
N341114: The country of origin of extension cords
| Origin: Thailand |
| Item: Indoor/outdoor extension cords. Each is comprised of a length of insulated conductor with a plug at one end and an illuminated receptacle at the other. The manufacturing process for all of the cables is substantially similar and occurs in Thailand through the following steps. Copper wire of Thai origin is twisted, pulled, and insulated via an extrusion process. The electrical plug and receptacle are then assembled and added to each end of the cable. The parts used to assemble the plug and receptacle, are sourced from China. The finished cords are then retail packaged for shipment to the United States. |
| Reason: The Thai-origin copper wire imparts the character of the finished articles. Further, the addition of the Chinese connectors does not substantially transform the insulated conductor into a new and different article of commerce with a name, character, and use distinct from the individual components. |
| Ruling Date: July 18, 2024 |
N341095: The tariff classification of nonalloy steel coils from Canada
| HTS: 7210.49.0091, free, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Other: Of a thickness of 0.4 mm or more." |
| Item: Zinc-coated nonalloy steel coils. The coils are hot-dipped galvanized and are made to ASTM A653. These cold-rolled nonalloy steel coils measure 0.71 mm or 0.86 mm in thickness and are 1219 mm in width. |
| Reason: Goods from Canada are exempt from Section 232 duties, and Section 301 duties will not apply since the coils do not originate in China. |
| Ruling Date: July 18, 2024 |
N341093: The tariff classification of nonalloy steel coils from South Korea
| HTS: 7210.49.0091, 9903.80.01, free + 25%, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Other: Of a thickness of 0.4 mm or more." |
| Item: Zinc-coated nonalloy steel coils. The coils are hot-dipped galvanized and are made to ASTM A653. These cold-rolled nonalloy steel coils measure 0.71 mm or 0.86 mm in thickness and are 1219 mm in width. |
| Reason: N/A |
| Ruling Date: July 18, 2024 |
N341087: The tariff classification of nonalloy steel coils from Canada
| HTS: 7210.49.0091, free, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Other: Of a thickness of 0.4 mm or more." |
| Item: Zinc-coated nonalloy steel coils. The coils are hot-dipped galvanized and are made to ASTM A653. These cold-rolled nonalloy steel coils measure 0.71 mm or 0.86 mm in thickness and are 1219 mm in width. |
| Reason: Goods from Canada are exempt from Section 232 duties, and Section 301 duties will not apply since the coils do not originate in China. |
| Ruling Date: July 18, 2024 |
N341223: The tariff classification of LED Drivers from China
| HTS: 8504.40.9510, 9903.88.03, free + 25%, “Electric transformers, static converters (for example rectifiers) and inductors; parts thereof: Static converters: Other: Rectifiers and rectifying apparatus: Power Supplies: With a power output not exceeding 50 W.” |
| Item: LED driver/emergency power apparatus that is installed in a light fixture to provide 90 minute backup power during a power loss. The LED Driver module takes supplied AC electricity and charges the battery that supplies power to the light fixture. The remote test switch assembly is used to test the circuit and provide a lighted indication when the batteries are being charged. |
| Reason: Goods put up in sets for retail sale, that cannot be classified by reference to GRI 3 (a), are to be classified as if they consisted of the component which gives them their essential character. The articles that provide the essential character of both sets are the driver boards, which convert and supply electricity for the operation of the lights while also charging the batteries. |
| Ruling Date: July 19, 2024 |
N341152: The tariff classification, country of origin and eligibility of the United States-Mexico-Canada Agreement (USMCA) of a polyethylene pouch with spout from Mexico
| HTS: 3923.21.0095, 3%, "Articles for the conveyance or packing of goods, of plastics: sacks and bags (including cones): of polymers of ethylene: other: other." |
| USMCA Eligibility: Eligible |
| Origin: Mexico |
| Item: A lightweight polyethylene pouch with an incorporated spout. It is printed and designed for transporting or packaging small amounts of juices, baby food, etc. for retail sale. The polyethylene film is manufactured and printed in China. Likewise, the plastic spout is manufactured in China. The polyethylene film and plastic spouts are shipped from China to Mexico for final processing. In Mexico, the film is unwound from rolls onto a processing machine that will precisely cut, and heat seal the film into pouches. The spouts are then incorporated into the finished pouches. |
| Reason: The polyethylene film as imported to Mexico from China is classified in 3920.10. The plastic spout, as imported to Mexico from China, is classified in 3926.90. Both components of the pouch meet the change in tariff requirement. Therefore, the polyethylene pouch with spout would be eligible for preferential tariff treatment under the USMCA. The polyethylene pouch with spout also meets the tariff shift requirement for country of origin marking. Therefore, the country of origin for marking purposes of the polyethylene pouch with spout will be Mexico. |
| Ruling Date: July 19, 2024 |
N341102: The tariff classification of nonalloy steel coils from India
| HTS: 7210.49.0091, 9903.80.01, free + 25%, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Other: Of a thickness of 0.4 mm or more." |
| Item: Zinc-coated nonalloy steel coils. The coils are hot-dipped galvanized and are made to ASTM A653. These cold-rolled nonalloy steel coils measure 0.71 mm or 0.86 mm in thickness and are 1219 mm in width. |
| Reason: N/A |
| Ruling Date: July 19, 2024 |
N341101: The tariff classification of nonalloy steel coils from Brazil
| HTS: 7210.49.0091, 9903.80.01, free + 25%, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Other: Of a thickness of 0.4 mm or more." |
| Item: Zinc-coated nonalloy steel coils. The coils are hot-dipped galvanized and are made to ASTM A653. These cold-rolled nonalloy steel coils measure 0.71 mm or 0.86 mm in thickness and are 1219 mm in width. |
| Reason: N/A |
| Ruling Date: July 19, 2024 |
N341099: The tariff classification of nonalloy steel coils from Japan
| HTS: 7210.49.0091, 9903.80.01, free + 25%, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Otherwise plated or coated with zinc: Other: Other: Of a thickness of 0.4 mm or more." |
| Item: Zinc-coated nonalloy steel coils. The coils are hot-dipped galvanized and are made to ASTM A653. These cold-rolled nonalloy steel coils measure 0.71 mm or 0.86 mm in thickness and are 1219 mm in width. |
| Reason: N/A |
| Ruling Date: July 19, 2024 |