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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N345342: The tariff classification of the photovoltaic (PV) generators from China
| HTS: 8501.72.1000, 9903.88.02, 9903.45.25, 2.5% + 25%, “Electric motors and generators (excluding generating sets): Photovoltaic DC generators: Of an output exceeding 50 W: Of an output not exceeding 750 W.” |
| Item: The first item under consideration is the Panel V1 Kit, which is a monocrystalline PV panel consisting of an aluminum frame, tempered glass, encapsulated cells, a back sheet, and a junction box. Included in the Panel V1 Kit are two 3’ 10-gauge MC4 cable assemblies. The junction box has two MC4 compatible pigtails and the Panel V1 measures 39.44” by 65.55”. The Panel V1 Kit, which is intended to be used with recreational vehicles, has an output of 320 Watts at 60V and supplies electricity directly to an inverter and/or battery. There are no inverters, or batteries included in the Panel V1 Kit. The second item under consideration is the Panel V2 Kit, which is a monocrystalline PV panel consisting of an aluminum frame, tempered glass, encapsulated cells, a back sheet, and a junction box. Included in the Panel V2 Kit are two 3’ 10-gauge MC4 cable assemblies. The junction box has two MC4 compatible pigtails and the Panel V2 measures 44.6” by 78.7”. The Panel V2 Kit, which is intended to be used with recreational vehicles, has an output of 470 Watts at 72V and supplies electricity directly to an inverter and/or battery. There are no inverters or batteries that are included in the Panel V1 Kit.The third item under consideration is the Panel V3 Kit, which is two monocrystalline PV panels, each consisting of an aluminum frame, tempered glass, encapsulated cells, a back sheet, and a junction box. Included in the Panel V3 Kit are two 3’ 10-gauge MC4 cable assemblies. The junction boxes each have two MC4 compatible pigtails and both panels measure 39.5” by 60”. The Panel V3 Kit, described as two panels that are intended to be used with recreational vehicles, has an output of 560 Watts at 58V and supplies electricity directly to an inverter and/or battery. There are no inverters or batteries that are included in the Panel V3 Kit. |
| Reason: N/A |
| Ruling Date: Jan. 29, 2025 |
N345383: The country of origin of paper napkins
| Origin: Indonesia |
| Item: The items under consideration are packages of paper napkins, including “dinner napkins,” “luncheon napkins,” “beverage napkins,” and "tall-fold napkins," which come in a variety of sizes and folds. The bulk rolls of tissue paper are manufactured in Indonesia. The paper is White/Kraft paper: virgin; layer: 1/2; with a 12-18 GSM. These parent rolls of tissue paper, which measure in multiple widths from 330 mm up to 1960 mm and have a maximum roll diameter 1960 mm, are then sent to China, where the tissue paper is embossed, cut to size, folded, subjected to quality control, and packaged. |
| Reason: In China the tissue paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting, folding, and packaging. |
| Ruling Date: Jan. 29, 2025 |
N345384: The country of origin of toilet tissue
| Origin: Indonesia |
| Item: The item under consideration is toilet tissue. The toilet tissue comes in a variety of plies (single, double, and triple). The bulk rolls of tissue paper are manufactured in Indonesia. The tissue paper is White/Kraft paper: virgin; layer: 2; with 12.5-15 GSM. These parent rolls of tissue paper, which measure 2740mm/ 2760mmmm in width and have a maximum roll diameter 2760mm, are then sent to China, where the tissue paper is embossed, converted by cutting to width and length and re-rolling onto smaller tubes, subjected to quality control, and packaged. |
| Reason: In China the tissue paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, converting, and packaging. |
| Ruling Date: Jan. 29, 2025 |
N345385: The country of origin of hand towels
| Origin: Indonesia |
| Item: The items under consideration are packages of “hand towels." They come in either single or double ply with no fold. The bulk rolls of tissue paper are manufactured in Indonesia. The paper is White/Kraft paper: virgin; layer:1; with a 30-36 GSM. These parent rolls of paper, which measure 2750 mm in width and has a maximum roll diameter of 2750 mm, are then sent to China, where the paper is embossed, converted by cutting to width and re-rolling to length, subjected to quality control, and packaged. |
| Reason: In China the tissue paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting, rolling, and packaging. |
| Ruling Date: Jan. 29, 2025 |
N345479: The tariff classification of body jewelry from China
| HTS: (1) 7117.90.9000, 9903.88.15, 11% + 7.5%, “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Other.” (5) titanium belly rings “Pearl Accent,” “Paved Crystal Ball,” and “Polished Stone Ball,” 7117.90.7500, free, “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Of plastics.” (2), (3), (4) 7116.20.0500, 3.3%, “Articles of natural or cultured pearls, precious or semi-precious stones (natural, synthetic or reconstructed): Of precious or semiprecious stones (natural, synthetic or reconstructed): Articles of jewelry: Valued not over $40 per piece: Other.” (5) titanium belly ring “Plain Titanium Ball,” 7117.19.9000, 11%, “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other: Other.” |
| Item: Item number 1 is a titanium nose ring featuring a double-row structure with one row consisting of polished titanium beads and the other set with clear glass stones. Item number 2 is a stainless-steel belly ring featuring two heart shape charms. One charm is made of base metal and contains small plastic stones set around the edge. The other charm is made of a cubic zirconia (CZ) stone. Item number 3 is a brass belly ring, with a polished gold-tone coating, featuring a trio of CZ stones arranged in a cascading drop-style design. Item number 4 is a stainless-steel nose ring, with gold-tone finish, in a semi-open hoop design adorned with a row of small CZ stones. The nose ring features two polished spherical ends. Item number 5 includes four different belly rings made of titanium. The four different designs are as follows: “Plain Titanium Ball” is a titanium belly ring with two spherical ends. “Pearl Accent” is a titanium belly ring featuring a faux pearl. “Paved Crystal Ball” is a titanium belly ring featuring many small plastic stones. “Polished Stone Ball” is a titanium belly ring featuring a round, faceted plastic stone. |
| Reason: N/A |
| Ruling Date: Jan. 29, 2025 |
N345199: The tariff classification of polyvinyl chloride adhesive labels from Canada
| HTS: 3919.90.5060, 5.8%, self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics: other: other: other. |
| Item: The product under review consists of a pack containing two sheets of labels. One sheet contains a top lid label, and the other sheet contains a wrap-around label. The labels are composed of polyvinyl chloride backed with acrylate resin. The labels are designed to be affixed on the “Bring it Back Recycling Bins.” |
| Reason: N/A |
| Ruling Date: Jan. 28, 2025 |
N345209: The tariff classification of ROOTONIX Fresh Salt-Scalp Scaler from South Korea
| HTS: 3305.90.0000, free, “Preparations for use on the hair: Other.” |
| Item: ROOTONIX Fresh Salt-Scalp Scaler, packaged in a 6.76 fluid ounce container, is a salt scrub designed to exfoliate the scalp, remove dead skin cells and cleanse pores. The product label provided further describes the product as “Relieving Hair Loss Symptoms” and lists various ingredients including mineral salt, AHA (alpha hydroxy acid), biotin and hibiscus flower. |
| Reason: N/A |
| Ruling Date: Jan. 28, 2025 |
N345260: The tariff classification of ethylene-propylene-nonconjugated diene (EPDM) rubber profiles from China
| HTS: 4008.29.2000, 9903.88.03, 2.9% + 25%, plates, sheets, strip, rods and profile shapes, of vulcanized rubber other than hard rubber: of noncellular rubber: other: profile shapes. |
| Item: The product under consideration is a Rubber Cable Guide. It is composed of vulcanized ethylene-propylene-nonconjugated diene (EPDM) rubber. The EPDM rubber is extruded into a profile that is shaped to hold an electrical wire. The guide will retain the wire within the cavity of the t-channel of an automobile accessory such as a cargo rack. The guides are 305 mm in length, 22 mm in width and 7 mm in height. |
| Reason: N/A |
| Ruling Date: Jan. 28, 2025 |
N345268: The tariff classification of a costume from China and Vietnam
| 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: An adult-size costume identified as Sultry Sea Pirate, which consists of a pullover dress, corset with attached skirt and bandana and features a raw, unfinished neck with exposed elastic stitched on in a single line with long loose, straight stitching. A small center front opening is closed with ribbon ties loosely tacked. The elbow length sleeves, and hem bottom are raw and unfinished with jagged cut edges, giving a tattered appearance. The sleeves also have narrow exposed elastic that is stitched on in a single line with long, loose straight stitching. The flimsy waist has exposed elastic stitched directly to the dress with a single line of long, loose straight stitching. The dress is constructed with long, loose, straight stitching. |
| Reason: The flimsy man-made knitted textile dress provides the essential character of the set. |
| Ruling Date: Jan. 28, 2025 |
N345271: The tariff classification of a costume from China and Vietnam
| 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: An adult-size costume identified as Lion Jumpsuit with Mask, which consists of a jumpsuit, mitts, shoe covers, tie-on front fur chest piece and full head mask and features large, visible, loose overlock stitching around the neck and deep back opening. The back opening is extra deep to permit the wearer to step in to the jumpsuit but because of the depth, provides no modesty to the wearer. The back opening only has two pairs of thin string ties for closure, which will not prevent gapping. The long sleeves and leg openings are raw and unfinished. The jumpsuit is stitched with large, loose overlock stitching. |
| Reason: The flimsy man-made knitted plush textile jumpsuit with tail provides the essential character of the set. |
| Ruling Date: Jan. 28, 2025 |