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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N345685: The tariff classification of a generating set from Austria
| HTS: 8502.20.0085, 2%, “Electric generating sets…: Generating sets with spark-ignition internal combustion piston engines: Of an output exceeding 75 kVA.” |
| Item: The merchandise under consideration is the Jenbacher Type 6 Genset, Model J616, which is a gas-fueled generating set consisting of the engine, the generator, control panel, heat recovery systems, and numerous parts and components that make up the fully assembled machine. The J616 Genset produces a maximum electrical output of 20.1 MW with a maximum thermal output of 18.23 MW. |
| Reason: N/A |
| Ruling Date: Feb. 13, 2025 |
N345829: The classification of a media console from China
| HTS: 9403.60.8093, 9903.01.20, 9903.88.03, free + 10% + 25%, “Other furniture and parts thereof: Other wooden furniture: Other: Other: Other.” |
| Item: The subject article is the Mid Century Danish Modern Style Record Cabinet Credenza or Media Console Stand with Adjustable Shelves. It is a media cabinet that measures 60" (L) x 31" (H) x 18" (D), with two sliding doors in the front that open a storage compartment with a vertical middle divider, and one height-adjustable shelf on either side. The console is made of MDF covered in an ash wood veneer and sits on four solid tapered ash legs. It weighs approximately 100 lbs. and is made in China. |
| Reason: N/A |
| Ruling Date: Feb. 13, 2025 |
N345837: The tariff classification of a notebook from China
| HTS: 4820.10.2060, 9903.01.20, 9903.88.03, free + 10% + 25%, “Diaries, notebooks and address books, bound; memorandum pads, letter pads and similar articles: Other.” |
| Item: The item under consideration is a notebook containing 100 lined pages (50 sheets) glue-bound between rigid covers. On the front cover is printed the name of a university, and on the back cover is a corresponding QR code. The notebook includes an elastic band closure. The outer dimensions of the notebook measure approximately 3.74 inches by 5.51 inches. |
| Reason: N/A |
| Ruling Date: Feb. 13, 2025 |
N345865: The classification of a storage cabinet from China
| HTS: 9403.30.8090, 9903.88.03, 9903.01.20, free + 25% + 10%, “Other furniture and parts thereof: Wooden furniture of a kind used in offices: Other: Other.” |
| Item: The subject article is the MMT-SD-IV06 White/Beech Storage Cabinet, and is a rectangular storage cabinet measuring 31.5" (W) x 15.7" (D) x 29.5" (H). The cabinet is made of laminated composite board and is intended for home use to store office supplies and other household articles. The item has two lockable doors with metal handles that open out, a single interior shelf, and it sits on four short metal legs with plastic feet. The cabinet is shipped flat and is sold on websites such as Amazon, eBay and Wayfair. The cabinet weighs 48 lbs. and is made in China. |
| Reason: N/A |
| Ruling Date: Feb. 13, 2025 |
N343643: The tariff classification of Deoxyribonucleic Acid Sodium Salt (DNA-Na) from Japan
| HTS: 2934.99.9001, 6.5%, “Nucleic acids and their salts, whether or not chemically defined; other heterocyclic compounds: Other: Other: Other: Other: Other." |
| Item: The subject merchandise is deoxyribonucleic acid sodium salt (DNA-Na) extracted from salmon milt, CAS No. 68938-01-2. It will be used as a raw material for chemical synthesis. |
| Reason: N/A |
| Ruling Date: Feb. 12, 2025 |
N345225: The country of origin of wheel bearing kits
| Origin: Thailand and China |
| Item: The items under consideration are a wheel bearing kit containing a ball bearing and a wheel bearing kit containing a tapered roller bearing. Each kit consists of four separate unassembled components, which include a wheel bearing, a flange with associated bolts, a circlip, and a nut. The outer and inner rings with raceways as well as the flange are manufactured in Thailand, starting from the importation of raw materials. Additionally, the grease, anti-rust oil, and packing materials used in the assembly are locally sourced in Thailand. The cage, rolling elements, seal ring, dust cover, bolts, circlip, and nut are of Chinese origin and imported to Thailand for further processing. |
| Reason: Each kit consists of four unassembled components: the wheel bearing, flange, circlip, and nut. Based on the manufacturing processes in Thailand of the wheel bearing and flange, the items undergo a substantial transformation from raw pipes/materials into identifiable components. Thus, the country of origin of the wheel bearing and flange with the associated bolts will be Thailand. However, the circlip and nut are not transformed in any way and are separate components in the kit. As such, they will retain their country of origin as China. As a result, the country of origin of the wheel bearing kits will be Thailand and China. |
| Ruling Date: Feb. 12, 2025 |
N345226: The tariff classification of a woman’s sandal from China
| HTS: 6404.19.3760, 9903.01.20, 12.5% + 10%, “Footwear with outer soles of rubber, plastics, leather or composition leather and uppers of textile materials: Footwear with outer soles of rubber or plastics: Other: Footwear with open toes or open heels: Other: With uppers of textile material other than vegetable fibers and having outer soles with textile materials having the greatest surface area in contact with the ground, but not taken into account under the terms of additional U.S. Note 5 to this chapter: Other: For women.” |
| Item: An open toe, open heel, woman’s shoe that does not cover the ankle. The upper has straps consisting of woven polyester textile arranged in a V-shape. Each strap measures approximately 1-1/2 inches wide. They are secured to the outer sole unit on the medial and lateral sides, with a thong between the first and second toes. The rubber/plastics (Ethylene Vinyl Acetate) platform outer sole measures approximately 1-1/2 inches under the front of the foot and approximately 2 inches at the heel. Non-durable textile material has been flocked to the majority of the external surface area of the outer sole in contact with the ground. There is no foxing or foxing-like band. The FOB value is $3.95 per pair. |
| Reason: N/A |
| Ruling Date: Feb. 12, 2025 |
N345242: The tariff classification of girls’ garments from Bangladesh
| HTS: 6109.10.0037, 16.5%, “T-shirts, singlets, tank tops and similar garments, knitted or crocheted: Of cotton: Women’s or girls’: Underwear.” |
| Item: A girl’s tank-styled undershirt. It is packaged as a 4-pack, sold with coordinating briefs, and made for children taller than 86 cm. The sizes range from 1.5 - 2 years to 10 - 11 years. Three of the undergarments have a fiber content of 100% cotton, and one undergarment has a fiber content of 98% cotton and 2% viscose. The undergarments are constructed from a finely knitted single jersey fabric, which features assorted cat prints. The item is sleeveless, extends beyond the waist and features 1-3/8-inch-wide shoulder straps, picot trim at the neckline and armholes, a bow in the center of the front neckline, and a hemmed bottom. |
| Reason: N/A |
| Ruling Date: Feb. 12, 2025 |
N345286: The country of origin of ball joints
| Origin: Thailand |
| Item: The subject merchandise are Model 1 and Model 2 ball joints, which are designed to be used in passenger vehicle suspension systems. The ball joints are slightly different in their shape to fit different vehicle types. Model 1 contains a cylindrical housing, while Model 2 contains a flanged housing and a special nut. However, they follow the same production steps. Ball joints are a critical component in the suspension system of an automobile. The ball joints consist of a ball pin, housing, dust boot, end cap, snap ring, clip ring, grease, bearing, and nut. The ball pin blank and cylindrical/flanged housing blank are forged in China from steel bars, and imported to Thailand for further processing. In Thailand, the ball pin forging undergoes flat head end face and rough turning, flat length and lead center hole drilling, rod finish turning, head rough turning, pin hole drilling and milling, thread rolling, induction hardening, crack detection, finish coating, and polishing. Similarly, in Thailand the cylindrical housing forging undergoes flat face and turning, flat length and lead center hole drilling, rough inner hole drilling, finish turning, knurling, induction hardening, and surface treatment. The flanged housing forging undergoes rough and precise machining on the big hole and small holes, heat treatment, finish coating, and screw tapping. The end cap is made in Thailand from left over steel sheet scraps from China by stretching, forming, punching, finish coating, and laser marking. The finished ball pin, housing, and end cap are then combined together with the Thai sourced dust boot, grease, and bearing, and the Chinese sourced snap ring, clip ring, and nut (including the special nut for Model 2) to form the finished ball joint. |
| Reason: The ball pin forging, housing forging, and steel sheet scraps for the end cap undergo a major physical change and become functioning components of the ball joint, when they are further processed in Thailand. As a result, a substantial transformation occurs in Thailand. Therefore, the country of origin for the Model 1 and Model 2 ball joints will be Thailand for marking purposes. |
| Ruling Date: Feb. 12, 2025 |
N345325: The country of origin of a Koda Secure Digital (SD) memory card
| Origin: Taiwan |
| Item: The merchandise is the Koda Secure Digital (SD) memory card. This SD card has an internal memory size of 16GB and is used to store photos, video, sound, and file storage. It can be inserted into devices with SD card slots that read the memory card, such as computers, smartphones, digital cameras, etc. It will also be manufactured with memory sizes of 32GB (TM056), 64GB (TM057) and 128GB (TM058). The production of this SD card is performed in Taiwan and Vietnam. The production processes can be divided into three parts: printed circuit board assembly via a surface mount technology process (Taiwan), encapsulation process (Taiwan), and testing and final packaging (Vietnam). |
| Reason: Regarding the origin of the subject SD card, the PCBA with the memory chip imparts the dominant character of the device. The PCBA with the memory chip performs the primary and essential functions of the finished device. Further, all components that originate from outside of Taiwan are ancillary and, thus, are substantially transformed by the processes performed in Taiwan. Based upon these facts, the country of origin of the subject SD card will be Taiwan. |
| Ruling Date: Feb. 12, 2025 |