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:
N341280: The country of origin of a USB Hub
| Origin: China |
| Item: The USB-C 11-in-1 Hub, which is an aluminum enclosure containing a printed circuit board assembly (PCBA) that has multiple connection ports and sockets, such as USB, HDMI, SD card slots, and an RJ45 port. In use, the Hub is connected to an automatic data processing machine for the purpose of connecting peripherals, such as a mouse, keyboard, and/or monitor, as well as memory cards and network connectivity. The Hub is assembled in Taiwan by placing the PCBA into the aluminum housing, installing a plastic end cap, and conducting quality and functional testing. The PCBA is manufactured in China by soldering electronic components onto a bare printed circuit board. |
| Reason: The assembly of the PCBA in China by soldering individual electronic components onto a bare board results in a substantial transformation of the components to produce a PCBA of Chinese origin. Furthermore, the PCBA, which functions to interconnect the peripherals to the attached computing device, establishes the character of the Hub. The assembly of the Hub by inserting the PCBA into an aluminum housing and functional testing in Taiwan is not complex and does not substantially transform the PCBA into a different article of commerce with a new name, character, and/or use. |
| Ruling Date: July 26, 2024 |
N341279: The tariff classification of Cleaning Gel from China
| HTS: 3402.50.5100, 9903.88.03, free + 25%, "Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 3401: Preparations put up for retail sale: Other." |
| Item: A cleaning preparation in gel form, suitable for retail sale in its imported condition. This product will be used by consumers to primarily clean the interior of automobiles and computer keyboards. The Cleaning Gel consists of water, guar gum, xanthan gum, PVC powder, titanium dioxide, sodium methylcellulose, lavender scent, and isothiazolinone. |
| Reason: N/A |
| Ruling Date: July 26, 2024 |
N341244: The tariff classification of a linkage from Mexico
| HTS: 8708.80.6590, 2.5%, "Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” |
| Item: A linkage used with heavy duty trucks built for the transport of heavy loads. It is a component of an air suspension system and connects to the height control valve lever at its top, and to the truck axle at this bottom. The linkage is a rod made of low carbon, zinc-plated steel, with a steel stud bolt, lock washer grommet and hex nut on each end. When the actuating lever or control arm of the height control valve moves vertically upwards, the valve opens and supplies air to the air springs. When the actuating lever moves down, the valve’s exhaust port opens to vent air from the air springs. The vehicle is at the pre-set ride height and no airflow occurs when the control arm is in the horizontal position. |
| Reason: The linkage in question is a connection between an axle and a lever that actuates a height control valve. Moreover, it is not contributing to the valve’s function of regulating air. It is managing movement between the vehicle’s axle and the pneumatic valve’s actuating lever. Considering these factors, the linkage is not an integral component part of the height control valve, and therefore, is not classified as a part of a pneumatic valve within heading 8481. |
| Ruling Date: July 26, 2024 |
N341225: The tariff classification of artificial turf from China
| HTS: (1), (2) 5703.31.0060, 9903.88.03, 6% + 25%, “Carpets and other textile floor coverings (including turf), tufted, whether or not made up: Of other man-made textile materials: Turf: Other: In rolls of a width equal to or exceeding 1.0 meter, or in sheets measuring 1.0 meter or greater on any side.” |
| Item: Two types of artificial turf. (1) One type is made of monofilaments, measuring more than 67 decitex, of 100% polyethylene and strip of 100% polypropylene inserted into a 3-layer primary backing consisting of woven polypropylene, nonwoven fabric and mesh scrim. A secondary backing of green latex secures the tufts in place. (2) the second type is made from 100% polyethylene green monofilament extruded fibers, measuring more than 67 decitex, and 100% polypropylene beige strip inserted into a dual layer primary backing of woven polypropylene and a secondary backing of black polyurethane. Both the monofilament and strip are less than 1 mm in width. |
| Reason: Monofilament of Heading 5404 may generally be of any cross-sectional shape; however, strip of Heading 5404 must be flat and must be of an apparent width of 5 mm or less. While Style AG1 includes monofilament greater than 67 decitex with a cross-sectional measurement of both less than or equal to and greater than 1 mm, the essential character of the turf is the textile monofilaments that measure less than 1 mm and textile filament strip measuring less than 5 mm. Textile floor coverings constructed from tufting are classified under heading 5703. |
| Ruling Date: July 26, 2024 |
N340992: The tariff classification of a nonwoven laminated roofing underlayment from India
| HTS: 5603.14.3000, free, “Nonwovens, whether or not impregnated, coated, covered or laminated: Of man-made filaments: Weighing more than 150 g/m2: Laminated fabrics.” |
| Item: Fabric designated as GAF Tiger Paw. The fabric is a laminated roofing underlayment designed to protect residential and light construction roofing systems by preventing water intrusion. The fabric is composed of: A top layer of spunbond non-woven fabric of filament polypropylene fibers weighing approximately 90 g/m2. It is light grey in color with a diamond embossed pattern; A first lamination layer primarily of low-density polyethylene (“LDPE”) weighing approximately 18 g/m2, with a layer of aluminum foil weighing approximately 20 g/m2; A second lamination layer, like the first primarily of LDPE, weighing approximately 18 g/m2; The bottom layer, like the top layer, is a spunbond non-woven fabric of filament polypropylene fibers weighing approximately 40 g/m2. It also is light grey in color with a diamond embossed pattern. A backside anti-skid layer made of primarily polypropylene, and LDPE weighing approximately 21 g/m2. The total fabric weight is approximately 207 g/m2. |
| Reason: N/A |
| Ruling Date: July 26, 2024 |
N341574: The tariff classification of decorative brooms from Indonesia
| HTS: 4602.19.8000, 2.3%, "Basketwork, wickerwork and other articles, made directly to shape from plaiting materials or made up from articles of heading 4601…Of vegetable materials: Other: Other: Other: Other." |
| Item: A small, decorative broom consisting of a natural “reed grass” broom portion affixed to a bamboo handle. Both have very gagged, uneven tops, as the grass is not cut to a uniform length. The burnt orange broom includes a loop at the bottom of the handle for hanging. The brooms measure approximately 8 inches to 10 inches in length. The items are strictly for decorative purposes and will be marketed as such. |
| Reason: While brooms are specifically provided for under heading 9603, brooms intended for decorative purposes and not sweeping don't meet the definition of a broom and would be classified by their constituent material. |
| Ruling Date: July 29, 2024 |
N341481: The tariff classification of an aluminum food pan from China
| HTS: 7615.10.7155, 3.1%, “Table, kitchen or other household articles and parts thereof, of aluminum…: Table, kitchen or other household articles and parts thereof…Other: Cooking and kitchen ware: Not enameled or glazed and not containing nonstick interior finishes: Other…Other cookware: Other.” |
| Item: A deep-drawn food well pan designed to store and serve food and used in cafeterias and restaurant establishments. The square pan is made of extruded aluminum with an Aluminum Association Series Designation (AASD) of 1060. It measures approximately 13.679 inches in length, 21.763 inches in width, and 6.247 inches in height. The pan is approximately 0.737 millimeters in thickness and weighs approximately 2 lbs. |
| Reason: N/A |
| Ruling Date: July 29, 2024 |
N341472: The tariff classification of a pumpkin stencil and mask kit from China
| HTS: 9505.90.6000, free, "Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Other: Other." |
| Item: A kit consisting of eight different printed paper face designs used to carve the plain pumpkins and turn them into jack-o’-lanterns as well as eight different polyvinyl chloride (PVC) eye masks to decorate the jack-o’-lanterns. There are no carving tools in this kit, only the paper designs which measure approximately 10.5"W X 10"H and the PVC eye masks which measure approximately 7.25"W X 4.75"H. The paper designs are affixed to the plain pumpkins to provide guides for outlining and then carving the desired faces. The eye masks are used to decorate the jack-o’-lanterns and are specially made to coordinate with the position of the eyes in the paper designs. The kit will be marketed and sold exclusively for Halloween. |
| Reason: The pumpkin stencil and mask kit will be classified as a set for tariff classification purposes in accordance with GRI 3(b), with the essential character imparted by the PVC eye masks. |
| Ruling Date: July 29, 2024 |
N341424: The tariff classification of nonalloy steel coils from Canada
| HTS: 7210.70.6060, free, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Painted, varnished or coated with plastics: Other: Zinc coated or plated: Other." |
| Item: Zinc-coated nonalloy steel coils. These cold-rolled steel coils which are made to ASTM A653 are hot-dipped galvanized and two coats of primer paint are applied. The coils measure 0.71 mm or 0.86 mm in thickness and are 1150 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 29, 2024 |
N341357: The tariff classification of nonalloy steel coils from South Korea
| HTS: 7210.70.6060, 9903.80.01, 9903.80.12, free + 25%, "Flat-rolled products of iron or nonalloy steel, of a width of 600 mm or more, clad, plated or coated: Painted, varnished or coated with plastics: Other: Zinc coated or plated: Other." |
| Item: Zinc-coated nonalloy steel coils. These cold-rolled steel coils which are made to ASTM A653 are hot-dipped galvanized and two coats of primer paint are applied. The coils measure 0.71 mm or 0.86 mm in thickness and are 1150 mm in width. |
| Reason: N/A |
| Ruling Date: July 29, 2024 |