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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N345915: A country of origin determination on exam table paper
| Origin: Indonesia |
| Item: The subject articles are rolls of non-sterile, disposable paper used to protect exam tables and other surfaces in medical and veterinary settings. They will come in widths of 8”, 18” and 24” and lengths of 125’ to 225’. Twelve one-ply rolls are packaged together. The bulk rolls of paper are manufactured in Indonesia. The paper is White paper: virgin; with 21 GSM. These rolls of paper, which measure 8" to 24" in width and have a maximum roll diameter 71mm, with a core diameter of 41mm, are then sent to China, where they are cut to length and then re-rolled onto smaller Chinese-origin cardboard tubes for the individual selling units. |
| Reason: In China the paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by cutting and packaging. |
| Ruling Date: Feb. 26, 2025 |
N345937: The country of origin of lens assemblies
| Origin: Vietnam |
| Item: The merchandise at issue with this request is singlet and doublet spherical lens assemblies. The subject lenses are round in shape with the necessary curvature and coatings needed to provide the intended optical effects. After importation to the United States, the lenses will be used as the optical elements within a riflescope. The subject devices are also suitable for potential use in telescopes and microscopes. There are two separate manufacturing scenarios for the lenses. The process is the same for all lenses. In Scenario A, unworked optical glass in the form of pucks, sheets, bars, and rods, sourced from Japan and/or China is shipped to Vietnam. In Vietnam, these raw glass materials are cut to the desired, disk-like shape, which creates the lens blank. The lens blank then undergoes a grinding and milling procedure that creates the desired curvature of the lens. The lens is then shipped to China where it is smoothed, polished, centered, and coated before it is combined with metal rings, spacers and O-rings. This process completes the lens assembly that is sent to the U.S. for inclusion in the riflescopes. In Scenario B, the unworked glass in the form of pucks, sheets, bars, and rods is also cut, ground and milled in Vietnam. Further, in Vietnam, the curved lens is then smoothed, polished, centered and coated. This spherical lens is then sent to China where it is combined with the metal rings, spacers, and O-rings prior to being sent to the U.S. for inclusion in the riflescopes. |
| Reason: The cutting, milling, and grinding of the glass into a lens with the necessary curvature imparts the critical optical properties necessary to the function of the lens, as this curvature gives the lens its optical characteristics. In both scenarios stated above that function occurs in Vietnam. Further, the process performed in China does not substantially transform the products into new and different articles of commerce. The origin of the singlet and doublet spherical lens assemblies will be Vietnam. |
| Ruling Date: Feb. 26, 2025 |
N346010: The tariff classification of an activated carbon powder from China
| HTS: 3802.10.0050, 9903.88.03, 9903.01.20, 4.8% + 25% + 10%, “Activated carbon; activated natural mineral products; animal black, including spent animal black: Activated carbon: Other.” |
| Item: The instant item is an activated carbon powder that will be imported in bulk form. The powder originates from walnut shells, and that it is activated using phosphoric acid. |
| Reason: N/A |
| Ruling Date: Feb. 26, 2025 |
N345461: The tariff classification of an outdoor grill center from China
| HTS: 7321.11.6000, 9903.88.03, 9903.01.20, free + 25% + 10%, “Stoves, ranges . . . barbecues . . . and similar nonelectric domestic appliances, and parts thereof, of iron or steel: Cooking appliances and plate warmers: For gas fuel or for both gas and other fuels: . . . Other: Other.” |
| Item: The grilling center with grill consists of two connected cabinets on both sides with a gas grill incorporated in the middle. The grilling center with grill is made of powdered steel, and the cabinets feature a ceramic tabletop measuring 25 inches wide by 24 inches long. The overall dimensions of the grilling center with grill are 93 inches long x 24 inches wide x 49 inches tall. |
| Reason: N/A |
| Ruling Date: Feb. 25, 2025 |
N345626: The tariff classification of 3-piece spa set from China
| HTS: 9615.19.6000, 9903.01.20, 11% + 10%, “Combs, hair-slides and the like; hair pins, 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: Other.” |
| Item: The merchandise is a 3-piece spa set consisting of a headband and two wristbands. The wristbands are made of fleece fabric. The headband is made of semi-rigid plastic that is completely covered with velvet fabric. This set is packaged together in a plastic bag with a label indicating it is sold as a set. |
| Reason: The velvet fabric is the focal point of the headband. The underlying semi-rigid plastic band is completely covered over in velvet fabric and cannot be seen. The essential character of the headband is imparted by the velvet fabric. |
| Ruling Date: Feb. 25, 2025 |
N345754: The tariff classification of a four-piece endoscope kit from China
| HTS: (1), (2), (3) 8481.80.5090, 9903.88.03, 9903.01.20, 3% + 25% + 10%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Hand operated: Of other materials: Other.” (4) 8481.30.9000, 9903.88.01, 9903.01.20, 3% + 25% + 10%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Check (nonreturn) valves: Other.” |
| Item: The product in question is the STERIS Fuji700 4-PC Kit. The four items in the kit are a suction valve (1), an air/water valve (2), a biopsy valve (3) and an auxiliary water connector (4). The suction and biopsy valves, which control the flow of fluid, and the air/water valve, which controls the flow of air and fluid, are manually actuated and primarily of plastic material. The auxiliary water connector, which is primarily of plastic, features a check valve that prevents backflow during irrigation. The valves are intended to be solely used with FUJIFILM 700 Series Gastrointestinal Endoscopes. The four items are imported separately or packaged together ready for retail sale. |
| Reason: N/A |
| Ruling Date: Feb. 25, 2025 |
N345764: The tariff classification of a one-step step stool from China
| HTS: 7323.99.9080, 9903.88.03, 9903.01.20, 3.4% + 25% + 10%, “Table, kitchen or other household articles and parts thereof, of iron or steel; Other: Other: Not coated or plated with precious metal: Other: Other. Other.” |
| Item: The merchandise is the “step2bed.” It is a height-adjustable one-step step stool with two handrails and an LED light. It measures approximately 18 inches long by 32 inches wide by 32 inches high. The step2bed comprises one short steel handrail, one tall steel hand rail with an ethylene-vinyl acetate (EVA) plastic foam grip, a steel top step platform that contains a non-slip grip tape containing an outer layer of textured vinyl with backing material of polyvinyl chloride (PVC) plastic material, an adhesive layer with pressure sensitive adhesive (PSA), a steel crossbar, four steel adjustable leg assemblies, four rubber feet, steel mounting brackets, steel bolts, steel nuts, and an LED light sensor. The LED light operates on four AAA batteries, which are not included in the item. The LED light provides illumination and is mounted onto the steel crossbar. All of the steel components are 100% steel. The step2bed is designed to assist users in getting in and out of bed. The leg assemblies contain four height configurations, which allow the item to be adjusted for various bed heights. |
| Reason: Adding two handrails and LED light to a one-step step stool for the benefit of the handicapped is minimal and, therefore, insufficiently significant to alter its basic character of a one-step step stool. Adding the two handrails and an LED light to the one-step step stool would assist the elderly and disabled. Still, it is not explicitly for use by the handicapped for secondary classification purposes. Neither limited mobility nor pain in transitioning in and out of bed is necessarily an indication of handicap and can be caused by more transient issues, such as injury or recovery from surgery, a medical procedure, or an accident. In addition, there are limitations due to arthritis or a temporary state of decreased muscle strength or limited balance (which may or may not rise to the level of a chronic handicap), age, and disability. Also, the “step2bed” is sold on various e-commerce websites, specialty stores, and hardware stores to the general public or to individuals with a transient or acute condition that does not rise to the level of a chronic disability and not exclusively to the handicap. Articles for acute or transient disability are excluded from subheading 9817.00.96 by application of U.S. Note 4(b)(i), of Chapter 98, Subchapter XVII. Therefore, the secondary classification of subheading 9817.00.96 is precluded. |
| Ruling Date: Feb. 25, 2025 |
N345804: The tariff classification of an empty plastic aroma therapy tube assembly from China
| HTS: 3923.90.0080, 9903.01.20, 9903.88.03, 3% + 10% + 25%, “articles for the conveyance or packing of goods, of plastics: other: other.” |
| Item: The product under review is a plastic aroma therapy tube assembly. It comprises an outer tube, an inner tube and plug. They are composed of molded polypropylene and will be imported empty. The inner tube and outer tube are rounded at the top. The inner tube is open on the bottom and has a small hole in the rounded top. After importation, an aroma stick will be placed into the inner tube, through the open bottom, and the plug will be used to seal the aroma stick inside the inner tube. The outer tube will then be screwed over the inner tube/aroma stick/plug to create a finished nasal aroma therapy inhaler for retail sale. |
| Reason: N/A |
| Ruling Date: Feb. 25, 2025 |
N345826: The tariff classification of the RowMo, an accessory to exercise equipment, from China
| HTS: 9506.91.0030, 9903.88.15, 4.6% + 7.5%, “Articles and equipment for general physical exercise, gymnastics, athletics, other sports…or outdoor games…; parts and accessories thereof: Other: Articles and equipment for general physical exercise, gymnastics or athletics; parts and accessories thereof ... Other.” |
| Item: The product consists of two handle attachments and a clip designed to be used on a rowing machine for the purpose of exercise or training. The RowMo components attach to the existing handles of a rowing fitness machine giving the user a wider range of hand and wrist motion. Each handle attachment possesses a steel ring that slides over the existing rowing machine handles. The clip is then used to hold the rings in a fixed position, thus stabilizing the handles when the rowing equipment is in use. The RowMo is an accessory to fitness equipment that simulates the motion of rowing a boat, allowing users to perform a full-body workout. |
| Reason: N/A |
| Ruling Date: Feb. 25, 2025 |
N345850: The tariff classification and country of origin of an under sink water filtration system
| HTS: 8421.21.0000, free, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” |
| Origin: South Korea |
| Item: The item under consideration is the WD-10UA Single-Stage Carbon Block Under Sink Water Filtration System, which provides clean water directly from a faucet. The device connects to the cold-water line leading to the sink. The filter is designed to reduce chlorine, contaminates, and odor for better-tasting water. The filters are to be replaced by a consumer approximately every twelve months and discarded. The filter element is composed of a Chinese O-ring, upper cover, middle cover, bottom cover, sump, transparent protective film, and a South Korean carbon block. The kit contains a Chinese stainless-steel water supply pipe, timer, nuts, and Teflon tape. The connector contains a Chinese spring, screw, O-rings, ¼ craw, connector switch cover, connector switch, fixed ring, joint upper cover, joint cup holder, stent, and T-joint. |
| Reason: The assembly process performed in China is not considered complex and does not constitute a substantial transformation. While there are many different individual components, each component only performs a small function for the overall system. Additionally, the construction of the filter itself predominantly involves gluing, welding, and pressing various components into place. The combining of all of the parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration System, it is the origin of the carbon block, which is the essential component of the system. It is the carbon block from South Korea which requires considerable technical experience and customized equipment to produce. It is also the most expensive portion of the system and is the item performing the filtering of the water. Accordingly, for origin and marking purposes, the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration System will be South Korea, which is where the carbon block is manufactured. |
| Ruling Date: Feb. 25, 2025 |