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:
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
N343876: The tariff classification of cornhole game parts from Vietnam
| HTS: 9504.90.9080, free, Video game consoles and machines, articles for arcade, table or parlor games, including pinball machines, bagatelle, billiards and special tables for casino games; automatic bowling alley equipment; parts and accessories thereof: Other: Other: Other: Other. |
| Item: A collection of wooden parts of gameboards that are used in the game of cornhole. The cornhole gameboard parts include the deck board, leg, block, and short frame, which when assembled make up the game surface onto which the cornhole beanbags are thrown. The four components are cut from a 15 mm birch faced plywood, are routered as necessary, pre-drilled to specifications, sanded and then shipped to the U.S. for painting, finishing and assembly. |
| Reason: N/A |
| Ruling Date: Nov. 26, 2024 |
N343898: The tariff classification of Sugarcane Juice from Vietnam
| HTS: 2202.99.9120, 0.2c/L, Waters, including mineral waters and aerated waters, containing added sugar or other sweetening matter or flavored, and other nonalcoholic beverages, not including fruit or vegetable juices of heading 2009: Other: Other: Other: Other. |
| Item: The product is frozen 100% sugarcane juice. It will be imported into the United States in 300 ml plastic bottles. The Sugarcane Juice is marketed as a beverage. |
| Reason: N/A |
| Ruling Date: Nov. 26, 2024 |
N343907: The tariff classification of a ceramic trinket jar from China
| HTS: 6913.90.5000, 9903.88.15, 6% + 7.5%, “Statuettes and other ornamental ceramic articles: Other: Other: Other.” |
| Item: The trinket jar is made of glazed ceramic dolomite. The ceramic jar is shaped like a pumpkin and features a pink stem and a pink, orange, and white checkered pattern. It measures approximately 3.8 inches wide by 5.75 inches high by 3.8 inches long. This decorative dolomite ceramic trinket jar is intended to store trinkets, jewelry, and non-food items. |
| Reason: N/A |
| Ruling Date: Nov. 26, 2024 |
N343930: The tariff classification of pet grooming tools from China
| HTS: (1) 9615.19.4000, 28.8 cents per gross + 4.6%, "Combs, hair-slides and the like: hairpins, curling pins, curling grips, hair-curlers and the like, other than those of heading 8516, and parts thereof: Combs, hair-slides and the like: Other: Combs: Valued over $4.50 per gross." (2) 9603.90.8050, 2.8%, “brooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): Other: Other: Other.” (3) 8214.20.3000, 4%, “other articles of cutlery (for example, hair clippers, butchers' or kitchen cleavers, chopping or mincing knives, paper knives); manicure or pedicure sets and instruments (including nail files); base metal parts thereof: manicure or pedicure sets and instruments (including nail files), and parts thereof: cuticle or corn knives, cuticle pushers, nail files, nail cleaners, nail nippers and clippers, all the foregoing used for manicure or pedicure purposes, and parts thereof.” |
| Item: (1) The “Furminator Cat Undercoat Small Size Short Hair,” is a de-shedding tool for grooming cats. It features a stainless steel de-shedding comb, an ergonomic handle, and a button that releases the fur. (2) The “Furminator Dog and Cat Dual Brush,” is a grooming brush for grooming dogs and cats. It is comprised of a brush with metal bristles on one side and boar's hair bristles on the other side. (3) The “Furminator Dog and Cat Nail Clipper,” is a grooming tool designed for trimming a dog or cat’s claws and features stainless-steel cutting edges with a nail guide. |
| Reason: N/A |
| Ruling Date: Nov. 26, 2024 |
N343950: The country of origin of position sensors
| Origin: Malaysia and Philippines |
| Item: Crankshaft/camshaft position sensors comprised of a Hall Effect sensor integrated circuit (IC) within a plastic housing with a connection point at one end. The devices are used within the engine compartment of a vehicle and provide position and speed of the camshaft and crankshaft of the vehicle. This information is gathered by the Electronic Control Unit (ECU) of the vehicle for interpretation. The devices function as a transducer by creating a magnetic field that, when broken by the presence of a metal object (i.e. the engine part), creates and electrical signal that is then sent to the ECU.The manufacturing and assembly process is virtually identical for both items and occurs primarily in Thailand. The primary difference in the two items is the origin of the Hall Effect IC. The first is manufactured in Malaysia while, and the second is manufactured in the Philippines. For both parts, this Hall Effect IC is attached to a Printed Circuit Board (PCB), which originates in Thailand. This connection process includes bending the contacts and soldering them to the PCB. The PCB does not contain any other active elements and is only used as a connection point. The various plastic parts are then assembled around the sensor and the finished device is inspected and packaged for shipment to the U.S. |
| Reason: The Hall Effect IC imparts the character of the finished device. This IC provides the essential functions of the device. Further, the assembly process performed in Thailand is simple in nature and would not result in a substantial transformation of the individual components into new and different articles of commerce. Based upon the facts presented, the country of origin of the first position sensor will be Malaysia. The country of origin of the second position sensor will be the Philippines. |
| Ruling Date: Nov. 26, 2024 |
N343952: The country of origin of wheel speed sensors
| Origin: Thailand |
| Item: The two items at issue with this request are described as ABS wheel speed sensors for use in vehicles. The first item comprises an electromagnetic core within a housing with a connector at one end. The device is attached within the wheel of a vehicle in order to detect the speed of the wheel. This function is achieved by the device creating a magnetic field around the target wheel. As the wheel rotates, the magnetic field is broken and an electrical impulse is sent to the vehicle’s Electronic Control Unit (ECU) for interpretation of the wheel’s speed and rotation. The second item comprises a length of insulated wire with a Hall Effect sensor attached at one end. Like the first, this item is also attached within the wheel of a vehicle in order to detect the speed of the wheel. The Hall Effect sensor, which comprises a Hall Effect integrated circuit (IC), creates a magnetic field around the target wheel. The IC senses when the wheel rotates and passes through the field and sends an electrical signal through the attached cable to the ECU for interpretation.The manufacturing process for the first item is performed entirely in Thailand. The process begins with Thai originating lacquered wire being wrapped around the plastic coil frame, which also incorporates the electrical connection portion of the device. A magnet, also originating from Thailand, is then attached along with an iron core. This assembly is then encased within a metal housing prior to the sensing head being attached. The finished device is then inspected and packaged for shipment to the U.S.The manufacturing process for the second item also occurs in Thailand. This process begins with Thai originating insulated wire being cut to length and the ends prepared for the addition of the sensor element. The Hall Effect ICs, also of Thai origin, are then bent and installed within the molded sensor housing. The electrical terminals, which originate from China, are then added to the sensor housing before it is attached to the cable. |
| Reason: Regarding the origin of the subject sensors, the magnetic elements and IC components impart the character of the devices. These articles perform the primary and essential functions of the finished devices. Further, all components that originate from outside of Thailand are ancillary and, thus, are substantially transformed by the processes performed. The country of origin of the ABS wheel speed sensors will be Thailand. |
| Ruling Date: Nov. 26, 2024 |
N343953: The country of origin of speed sensors
| Origin: China |
| Item: There are two items at issue with this request that are both described as speed sensors for use within vehicles comprised of a Hall Effect sensor integrated circuit (IC) within a plastic housing with a connection point at one end. The devices are installed within the transmission system of a vehicle and provide speed information for the wheels and turbines within the system. This is accomplished by the sensors acting as a transducer by creating a magnetic field around the target wheel or turbine. As a target passes through the field, the Hall Effect IC registers this presence and transfers this to an electrical impulse that is sent to the Transmission Control Unit (TCU). The TCU then interprets and processes this signal into a speed for the wheel or turbine. This allows the transmission to effectively shift gears as the vehicle is in motion. The manufacturing process is virtually identical for the two models and occurs in Thailand. The Hall Effect IC, which in both cases is manufactured in China, is attached to a Printed Circuit Board (PCB) of Thai origin. This process consists of bending and soldering the leads of the IC to the PCB. Further, the PCB does not contain any other active elements and is only used as a connection point. The IC and PCB subassembly are then inserted into the plastic frame and enclosed with a plastic shell, which originates in Thailand. The finished device is then inspected, tested and packaged for shipment to the U.S. |
| Reason: Regarding the origin of the subject sensors, the Hall Effect IC imparts the character of the finished device. This IC provides the essential functions of the device. Further, the assembly process performed in Thailand is simple in nature and would not result in a substantial transformation of the individual components into new and different articles of commerce. Based upon the facts presented, the country of origin of the speed sensors will be China. |
| Ruling Date: Nov. 26, 2024 |
N343954: The country of origin of ride height sensors
| Origin: Thailand |
| Item: There are two items at issue with this request described as ride height sensors. These devices consist of a Printed Circuit Board (PCB) and magnetic core within an enclosure equipped with brackets and rocker arms for mounting purposes. These devices are mounted within the suspension system of a vehicle in order to detect differences in the height of the wheels and other suspension parts. The subject sensors act as transducers by creating a magnetic field within the suspension system. When the suspension compresses or expands, the magnetic field is broken creating an electrical signal that is sent to the Electronic Control Unit (ECU) of the vehicle for interpretation. This information is used to activate and enhance the active suspension systems throughout the vehicle.The manufacturing process is substantially similar for both models and occurs in Thailand. The PCB and magnetic core, which originate from Thailand, are installed within the molded body. The electrical connection components and rocker/mounting arms are then added to the body. We note that the molded body and mounting arms also originate from Thailand while the screws that mount the arms originate from China. The finished device is then inspected, tested and packaged for shipment to the U.S. |
| Reason: Regarding the origin of the subject sensors, the PCB and magnetic core impart the character of the finished device as they perform the essential function of the sensors. Further, all components that originate from outside of Thailand are ancillary and, thus, are substantially transformed by the processes performed. Based upon the facts presented, the country of origin of the ride height sensors will be Thailand. |
| Ruling Date: Nov. 26, 2024 |
N344025: The tariff classification of electric motors from China
| HTS: 8501.10.4060, 9903.88.01, 4.4% + 25%, “Electrical motors and generators (excluding generating sets): Motors of an output not exceeding 37.5 W: Of under 18.6 W: Other: DC: Other.” |
| Item: There are three electric motors under consideration, identified as the HSWS Motor, the HSWS Motor, and the HSWS Motor, which are described as brushed DC electric motors with a maximum power output of 1.26 Watts. The subject motors are intended to be installed within a vehicle’s steering wheel to provide for haptic sensory feedback to the driver. The three motors operate on 12 VDC and measure 20 mm in diameter. |
| Reason: N/A |
| Ruling Date: Nov. 26, 2024 |
N344049: The tariff classification of an electrical connector from China
| HTS: 8536.69.4040, 9903.88.01, free + 25%, “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits…for a voltage not exceeding 1,000 V: Lamp-holders, plugs and sockets: Other: Coaxial connectors…rack and panel connectors; printed circuit connectors; ribbon or flat cable connectors: Printed circuit connectors.” |
| Item: Receptacle VT, which is described as a modular electrical connector designed to mount to a flexible or rigid printed circuit. The Receptacle VT is constructed of a plastic housing with two rows of 15 electrical sockets and corresponding contact pins that are oriented so that the header is mounted vertically. |
| Reason: N/A |
| Ruling Date: Nov. 26, 2024 |