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:
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N344179: The country of origin of a switching power supply
| Origin: Vietnam |
| Item: The Switching Power Supply MWE Gold 750W V3, which is a metal enclosure having five printed circuit board assemblies (PCBAs), numerous electrical connectors, a cooling fan, a fuse, multiple wire harnesses, multiple heat sinks, four copper brackets, insulating Mylar inserts, heat shrink tubing, labels, fastening hardware, and shipping carton materials. The power supply is used as a primary source of power for personal computers. The first PCBA, noted as the Motherboard, converts AC electricity to DC. The second PCBA provides for the interface and control of switches and signals. The third PCBA is described as a voltage conversion board. The fourth PCBA is described as a fan control board. The fifth PCBA is described as the power output board.The PCBAs are all assembled in Vietnam by soldering numerous individual components of various origins, such as capacitors, resistors, integrated circuits, transistors, connectors, relays, diodes, transformers, chokes, and more onto bare printed circuit boards by a surface mount and through hole insertion process. Also in Vietnam, the power supply is assembled, tested, and packaged for export. |
| Reason: Regarding the origin of the subject power supply, the assembly of the PCBAs in Vietnam by soldering the individual components of various origins onto bare boards results in a substantial transformation of those components to produce the six PCBAs of Vietnamese origin. Furthermore, it is the Motherboard PCBA that establishes the function of the power supply because it is the article within the assembly that converts the electricity from AC to DC. As a result of the forgoing, the components that make up the power supply are substantially transformed in Vietnam into a new and different article of commerce, and the Switching Power Supply MWE Gold 750W V3, is considered a product of Vietnam for origin and marking purposes at time of importation into the United States. |
| Ruling Date: Dec. 10, 2024 |
N344204: The Country of Origin of Processed Crabmeat
| Origin: Vietnam |
| Item: Red Swimming Crabs (Monomia haanii previously Portunus haanii) which will be caught on the coast of China and then shipped whole and frozen to Vietnam where they will be thawed, cooked, and the meat will be handpicked and packed in cans. The cans will be sealed, pasteurized, refrigerated and then sold to the food service industry upon importation to the United States. |
| Reason: Regarding the above-described processed crabmeat product, the article is substantially transformed due to processing that is performed in Vietnam, since the removal of crab meat from frozen crab parts and the subsequent sorting, packing, cooking, canning, and packing of cans creates a new and different product. Accordingly, based on the information presented, the crabmeat is a product of Vietnam. |
| Ruling Date: Dec. 10, 2024 |
N344206: The country of origin and applicability of Section 301 Trade Remedies of Junction Blocks
| Origin: Korea |
| Item: Two items that are identified as the Junction Block Assy-HI/VLT, which are both described as an enclosure with internally mounted fuses, bus bars, a relay, wiring, and hardware. The Junction Blocks are used in electric vehicles to provide high voltage electrical connections between the vehicle electrical systems and the high powered inverter.The relay is sourced from Japan, while the balance of all materials used in the manufacturing of the Junction Blocks, such as the fuses, the bus bars, the enclosure, and the hardware, are sourced from Korea. In Korea, the electrical apparatus and wire are mounted inside the enclosure and bolted in place, the Junction Blocks are inspected, tested, and packaged for export to the United States. |
| Reason: Regarding the country of origin of the Junction Blocks, the assembly operations performed in Korea, which consists mainly of inserting and fastening the components into a housing, are neither complex nor do they substantially transform the articles being assembled. However, the Korean origin bus bars and fuses produce the function of the device because they are the articles within the assembly that are making the electrical connections between the vehicle’s inverter and the electric motor(s). While the Japanese origin electrical relay also contributes to the electrical connection function, the fuses and bus bars, in sum with the assembly operations in Korea, establish the origin of the finished Junction Blocks as electrical connection apparatus. Therefore, based upon the facts presented, the Junction Blocks Assy-HI/VLT, are considered products of Korea for origin and marking purposes at time of importation into the United States. Lastly, as no components are of Chinese origin, nor is any assembly work conducted in China, the Junction Blocks are not subject to Section 301 trade remedies upon importation into the United States. |
| Ruling Date: Dec. 10, 2024 |
N344211: The country of origin of plastic syringes with needles
| Origin: Cambodia |
| Item: The imported plastic syringes with needles are for animal use only. In South Korea, Chinese hollow steel tubes will be cut to length and cut or sharpened to a sharp tip on one end, resulting in a basic steel needle. Then the needles will be exported to China, where a hub will be attached to the blunt end with adhesive. The hubbed needles will be exported to Cambodia for final production. In Cambodia, the syringe parts (barrels with tips, plungers, and plunger seals) are individually molded from plastic and then assembled. The graduating marking will be printed on the barrels in Cambodia. The hubbed needles will be screwed in the tips of the syringes. Chinese plastic caps (if present) will be attached to the needles. The finished syringes with needles will be packaged, sterilized, and then exported to the United States. |
| Reason: In this case, the assembly of the final syringes and the manufacture of the syringe parts from plastic in Cambodia when considered together create a new article with a new name, use, and character and constitute a substantial transformation. As such, the country of origin of the complete syringes with needles is Cambodia. |
| Ruling Date: Dec. 10, 2024 |
N344229: The tariff classification of an insulated cooler bag from Cambodia
| HTS: 4202.92.1000, 3.4%, insulated food and beverage bags, with outer surface of sheeting of plastic or of textile materials, other. |
| Item: An insulated cooler bag with two shoulder straps. The exterior of the bag is comprised of thermoplastic elastomer (TPE). There is a layer of foam plastic between the lining and the outer layer. The article is designed to provide storage, protection, organization, and portability to food and beverages during travel. It is also designed to maintain the temperature of food and beverages. It features five insulated compartments, seven pockets, and seven accessory pockets. The article measures approximately 12 inches (L) x 19 inches (W) x 20 inches (H). The insulated backpack is imported with two ice packs. |
| Reason: The insulated cooler bag and ice packs are considered composite goods in accordance with General Rule of Interpretation (GRI) 3(b) HTSUS. The essential character is imparted by the insulated cooler bag as that is the principal component which predominates in weight and bulk. Moreover, the insulated bag is fully functional with or without the ice packs. The ice packs are optional components that will be used as needed. |
| Ruling Date: Dec. 10, 2024 |
N344246: The country of origin of a gaming desk
| Origin: Vietnam |
| Item: The desk is identified as the RS Gaming Chronos 66" W Height-Adjustable Gaming Desk with Integrated Power and Charging (Black). The desk measures 66" wide, 30" deep, and it can be electronically adjusted from 29" high to 47" high. The desktop is made of edge-banded MDF with a carbon-fiber-finish laminate surface, and the chassis is made of powder-coated steel.The manufacturing operations performed in Vietnam on the Chinese materials and the addition of Vietnamese components amount to a substantial transformation and result in the creation of a distinct article with a new name, character and use, and that this is not simply an assembly operation. |
| Reason: Based upon the foregoing set of facts, none of the Chinese components involved in making the gaming desk provide the essence of the gaming desk. Rather, they do not constitute the gaming desk until they undergo the further processing and are combined with Vietnamese origin materials in Vietnam. The Chinese-made metal side column tubes, metal tube feet, metal cable box, metal frame, MDF tabletop (main), MDF tabletop (mouse), hand controller and accessory are imported into Vietnam for further processing and/or assembly with Vietnamese materials. In Vietnam, the metal side column tubes undergo welding, grinding and powder coating to produce the side column assemblies. Motors are installed and the columns are tested. The metal frame undergoes welding and powder coating. The tabletop and frame are assembled with the wireless charger, hand controller, RGB lights, power box and accessory. The complete unassembled gaming table is cleaned and packaged for export. These manufacturing operations performed in Vietnam substantially transform the Chinese components and materials and result in the creation of a distinct article with a new name, character and use. Accordingly, the country of origin of the gaming desk is Vietnam. |
| Ruling Date: Dec. 10, 2024 |
N344289: The tariff classification of steel sheets from South Korea
| HTS: 7326.19.0080, 2.9%, other articles of iron or steel: forged or stamped, but not further worked: other. |
| Item: Pre-cut steel sheet, which is a raw material. Prior to importation the raw material will undergo a blanking/stamping process performed in South Korea to produce the steel sheet in condition as imported into the United States. The raw material “goes through press processing (blanking) with a special mold made to match the width and thickness of the steel sheet…and cutting in the process is cutting to create the necessary parts (cutting in a state where there is no identifiable shape).”The blanking process produces individual steel sheets that measure 1680 millimeters in width by 630 millimeters in length, by 1.2 millimeters in thickness. The two parallel sides are not straight lines but have a wave shape. Along the length each steel sheet has straight edge while along the width it has a wavy pattern. This product is shipped from South Korea after several sheets are stacked and packaged. Once imported the steel sheets will be further worked and used in the manufacture of automobile parts. |
| Reason: N/A |
| Ruling Date: Dec. 10, 2024 |
N343994: The tariff classification of scalp massager from China
| HTS: 9603.29.8010, 0.3¢ each + 3.6%, “[b]rooms, 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): [t]oothbrushes, shaving brushes, hair brushes, nail brushes, eyelash brushes and other toilet brushes for use on the person, including such brushes constituting parts of appliances: [o]ther: [v]alued over 40¢ each: [h]airbrushes.” |
| Item: A circular molded plastic scalp massager, with bristles on one side to massage the scalp, and a handle on the reverse side. The handle has a depiction of “Cinnamoroll,” a character in the Hello Kitty world. |
| Reason: N/A |
| Ruling Date: Dec. 9, 2024 |
N344027: The country of origin of Bumetanide Tablets USP, in dosage form
| Origin: Italy |
| Item: Bumetanide, imported in 0.5 mg, 1 mg and 2 mg tablets, is a diuretic. It is indicated for the treatment of edema associated with congestive heart failure, hepatic and renal diseases, including the nephrotic syndrome.The active pharmaceutical ingredient (API), Bumetanide, is manufactured in Italy and the finished tablets in dosage form are made in India. In India, the Bumetanide will be mixed with various inactive ingredients to produce the final tablets in dosage form. |
| Reason: In this case, the mixing of the active ingredient Bumetanide (made in Italy) with the inactive ingredients into the final dosage tablets in India does not result in a substantial transformation and the country of origin will be Italy. |
| Ruling Date: Dec. 9, 2024 |
N344082: The country of origin of a wheel hub unit
| Origin: Thailand |
| Item: The article under consideration is a wheel hub unit, the “G3 ball hub bearing unit.” It is a component of automotive wheels, which is connected to the axle through bearings, carrying the weight of the entire vehicle. When the vehicle is in motion, the weight is transmitted to the ground through the wheel hub to support and stabilize the vehicle's movement. The wheel hub unit is connected to the engine through a transmission system (such as traditional drive shafts or modern electric drive systems), allowing the driving force generated by the engine to be converted into the rotational force of the wheels, thereby driving the vehicle forward or backward. The wheel hub unit absorbs impacts and vibrations from uneven roads through its internal shock absorption system (such as suspension devices), protecting the vehicle and passengers from the impact of bumps and vibrations, and providing a comfortable driving experience.The wheel hub unit is composed of internal and external bearings, sealing rings, and other components. The inner ring, outer ring (outer flange) and mandrel (inner flange) are made in Thailand, while the balls, cage, sealing ring, bolts, magnetic component, and grease are imported from China to Thailand for the final assembly. In Thailand, the Thai and Chinese components are cleaned, demagnetized, and laser marked. The bolts and pins are pressed into the flange. The inner groove is graded; steel balls are installed; and the oil is injected into the raceway. Then, the components are pressed in together and riveted, which completes the assembly process. |
| Reason: In the present case, the assembly of the components in Thailand is not complex enough to render a substantial transformation of the components. None of the components undergo a physical change in Thailand as a result of the assembly, except for becoming a part of a complete wheel hub unit. As a result, the character of the entire article grant the "essence" of the item. In this case, the Thai inner and outer rings and mandrel are the character of the entire wheel hub unit. Therefore, the country of origin of the “G3 ball hub bearing unit” will be Thailand for marking purposes. |
| Ruling Date: Dec. 9, 2024 |