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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N346051: The tariff classification of electric actuators from China
| HTS: 8501.31.2000, 9903.88.01, 9903.01.24, 2.8% + 25% + 20%, “Electric motors…: Other DC motors; DC generators: Of an output not exceeding 750 W: Motors: Exceeding 37.5 W but not exceeding 74.6 W.” |
| Item: The three items under consideration are Linear Actuators. Each of the actuators consists of a brushed 50 W DC motor, a plastic shaft covering two metal ends and a wiring harness. The actuators are designed to be used in vehicle lift applications for handicapped or disabled access to personal vehicles. |
| Reason: N/A |
| Ruling Date: March 7, 2025 |
N346114: The tariff classification of an electrical cable from China
| HTS: 8544.42.9090, 9903.01.24, 9903.88.03, 2.6% + 25% + 20%, “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Other electric conductors, for a voltage not exceeding 1,000 V: Fitted with connectors: Other: Other: Other.” |
| Item: The merchandise under consideration is an electrical cable, which is used in the Zulu 3 and Sierra headsets within the general aviation industry. The cable comprises a red wire and a black wire joined together by an electrical connector at one end, while the opposite ends are unterminated and stripped of insulated covering. The cable is used within the headset to convert power transmitted from the AA battery, providing voltage to the control box that powers the headset and provides noise canceling capabilities. |
| Reason: N/A |
| Ruling Date: March 7, 2025 |
N346162: The country of origin and marking of a gold, diamond, and gemstone ring
| Origin: Thailand |
| Item: The merchandise under consideration is a gold, diamond, and gemstone ring. The gold ring will be cast in Thailand. The ring casting is then sent to China where it undergoes cleaning and polishing, stone setting and final adjustments, and packaging before being sent to the United States. |
| Reason: The casting of the ring in Thailand provides the essence of the finished product. The finishing and setting of stones in China does not substantially transform the casting. As a result, the country of origin of the ring is Thailand. The proposed marking of the gold ring using a hang tag or an adhesive sticker will be an acceptable method of marking the ring with its origin of Thailand. |
| Ruling Date: March 7, 2025 |
N346285: The tariff classification of electric motors from China
| HTS: (1), (3), (4) 8501.10.6060, 9903.88.02, 9903.01.24, 2.8% + 25% + 20%, "Electric motors…: Motors of an output not exceeding 37.5 W: Of 18.65 W or more but not exceeding 37.5 W: DC: Other." (2) 8501.31.2000, 9903.88.01, 9903.01.24, 2.8% + 25% + 20%, “Electric motors…: Other DC motors; DC generators: Of an output not exceeding 750 W: Motors: Exceeding 37.5 W but not exceeding 74.6 W”." (5) 8501.10.4060, 9903.88.01, 9903.01.24, 4.4% + 25% + 20%, “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: The first item under consideration is the PHA2000 ASM, which is a brushed DC electric gear motor consisting of a DC electric motor and an attached gear and mounting bracket assembly. The PHA2000 ASM is to be used in motor vehicle seat applications and has a calculated maximum output of 25 Watts. The second item under consideration is the PHA3000 ASM, which is a brushed DC electric gear motor consisting of a DC electric motor and an attached gear and mounting bracket assembly. The PHA3000 ASM is to be used in motor vehicle seat applications and has a calculated maximum output of 38 Watts. The third item under consideration is the Tilt2000P ASM, which is a brushed DC electric gear motor consisting of a DC electric motor and an attached gear and mounting bracket assembly. The Tilt2000P ASM is to be used in motor vehicle seat applications and has a calculated maximum output of 25 Watts. The fourth item under consideration is the Mini Tilt ASM, which is a brushed DC electric gear motor consisting of a DC electric motor and an attached gear and mounting bracket assembly. The Mini Tilt ASM is to be used in motor vehicle seat applications and has a calculated maximum output of 26 Watts. The fifth item under consideration is the RTA2000 ASM, which is a brushed DC electric gear motor consisting of a DC electric motor having an output shaft with a threaded collar. The RTA2000 ASM is to be used in motor vehicle seat applications and has a calculated maximum output of 14 Watts. |
| Reason: N/A |
| Ruling Date: March 7, 2025 |
N344673: The tariff classification of a polyoxypropylene diamine from Taiwan
| HTS: 3824.99.9397, 5%, "Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Other: Other: Other: Other." |
| Item: The item under consideration is a polyoxypropylene diamine. It has an average of 2.5 repeating monomer units. The instant product will be a curing agent primarily for epoxy systems. |
| Reason: N/A |
| Ruling Date: March 6, 2025 |
N345899: The country of origin of an LED emergency light
| Origin: India |
| Item: The LED emergency light consists of a plastic back plate, batteries, a main printed circuit board assembly (PCBA), a plastic housing (to which two LED lamps or light heads are attached), two plastic lamp housings, two LED PBCAs (one for each lamp), a reflector and two lenses. The LED PBCAs are populated with LEDs forming the LED light boards (light source). All of the components and materials are from China except for the main PCBA and the LED light boards (light source) which are made in India. The PCBAs are manufactured in India, which starts with the designing and production of the PCBs. The PCBs are then populated with the imported electronic components via the SMT (surface mount technology) process to make the PCBAs. The SMT process involves mounting the various electronic components, e.g., capacitors, varistors, fuses, diodes, etc., which goes through the steps of first surface-mount devices (SMD), through hole components manual soldering, SMD soldering, and through hole (TH) component soldering. In particular, the PCBAs for the light heads are populated with the LEDs to make the LED light boards (light source) in India during the process. The final assemblies include assembling all the imported components together with the PCBAs (including the LED light boards), firmware loading and testing to make the finished emergency lights. |
| Reason: Although a significant number of the parts or components are made in China, the PBCAs (including light source) are the most important and critical components in the subject LED emergency light. The assembly operations, especially the SMT process, performed in India are complex and meaningful. The substantial transformation occurs. Therefore, the country of origin of the LED emergency light is India, China Section 301 remedies do not apply. |
| Ruling Date: March 6, 2025 |
N345938: The country of origin of a hair clipper kit
| Origin: Vietnam |
| Item: The merchandise at issue is a cordless hair clipper kit, which consists of a cordless electric hair clipper, oil bottle, charging cord and plastic comb attachments. The hair clipper has a rectangular body with slightly rounded edges. It features a two-tone black and silver color scheme. The side of the hair clipper includes a power switch and an adjustable taper lever for customizing cutting lengths. The hair clipper also has a charging plug at the bottom for power and a contoured shape designed for handling. There are two manufacturing scenarios, which are identical except for the motor’s country of origin, i.e., in Scenario 1, the motor is made in China and in Scenario 2, the motor is made in Vietnam. The Chinese origin components are the battery, scissors and fixed knife assembly. All other components are made in Vietnam. These components include the PCBA (printed circuit board assembly), charging cable, charging plug, wires, metal components (screws and nuts, cover, springs, gasket), etc.; and the plastic components (lower and upper shells, switch, slider, blade holder, adjusting lever, combs, etc.). The PCBA is fabricated through the surface mount technology (SMT) in Vietnam. SMT is a process whereby dozens of components are directly mounted onto a PCBA using solder paste and automated placement. Reflow soldering then secures the components, enabling high-density, efficient electronic assembly. The other components are fabricated in Vietnam through a variety of machining, pressing, and soldering operations. The operations encompass metal cutting and stamping, heat treatment, metal furnace injection molding, and plastic injection molding. |
| Reason: A significant number of the parts or components are made in Vietnam, the manufacturing operations, including the SMT process, plastic injection and metal molding, are complex and meaningful. The manufacturing process in Vietnam does create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Vietnam. Therefore, the country of origin of hair clipper kit is Vietnam for both scenarios, and the China Section 301 remedies do not apply. |
| Ruling Date: March 6, 2025 |
N345996: The tariff classification, country of origin, and marking of an Ignition Coil
| HTS: 8511.30.0080, 2.5%, “Electrical ignition or starting equipment of a kind used for spark-ignition or compression- ignition internal combustion engines (for example,…ignition coils,…);…of a kind used in conjunction with such engines; parts thereof: Distributors; ignition coils: Ignition coils.” |
| Origin: Thailand |
| Item: The item under consideration is an Ignition Coil for an automotive engine, sometimes referred to as a spark coil, which is used to provide electrical energy to the spark plugs. This product includes a plastic housing, copper wire, plastic skeleton, iron core, module, and rubber boot. The ignition coils incorporate an electrical transformer, which is used to produce high-voltage pulses from a low-voltage direct current (DC) supply in an automobile's ignition system which transforms the vehicle’s low voltage to the thousands of volts needed to create the electric spark that ignites the fuel. |
| Reason: The Ignition Coil’s components and subassemblies are substantially transformed during the manufacturing process in Thailand and thus the country of origin of the complete Ignition Coil is Thailand for marking purposes. As the country of origin of the subject item is Thailand, the Section 301 Trade Remedy duties are not applicable to the Ignition Coil under consideration. Thailand has been determined as the country in which the product was produced, therefore the Ignition Coil may be marked “Made in Thailand.” |
| Ruling Date: March 6, 2025 |
N346196: The tariff classification of four laminated nonwoven fabrics from India
| HTS: 5603.12.0095, free: “Nonwovens, whether or not impregnated, coated, covered or laminated: Of man-made filaments: Weighing more than 25 g/m2 but not more than 70 g/m2.” |
| Item: The nonwoven articles are lightweight nonwoven fabrics composed of man-made filament fibers; each fabric is of similar construction and weight. The laminated nonwovens feature a layer of plastic sandwiched between nonwoven fabrics. The fabrics will be imported on rolls from India and used to make surgical drapes, gowns and similar items. |
| Reason: N/A |
| Ruling Date: March 6, 2025 |
N346235: The tariff classification of a letters to Santa kit from China
| HTS: 4820.10.2020, 9903.01.20, 9903.88.03, free + 25% + 10%, “Registers, account books, notebooks, order books, receipt books, letter pads, memorandum pads, diaries and similar articles: Memorandum pads, letter pads and similar articles.” |
| Item: “Letters to Santa Children’s Activity Set,” is a folio containing items necessary for children to write and decorate letters to Santa Claus. Inside is a pad of 15 sheets of lined paper, measuring 5.25” x 11.25” and glue bound at the top to a cardboard backer. Many sheets have small, Christmas-themed illustrations, and some also include an area for the child to draw a picture. On their reverse side, the paper sheets are printed to resemble an envelope, so that when folded, the child can address it to look like a letter ready to mail. Also in the folio are 4 crayons; 1 marker; 2 sheets of Christmas-themed, lithographically printed paper stickers; 1 sheet of Christmas-themed, non-lithographically printed holographic paper stickers; and two self-adhesive paper nametags reading “Tried to be on the nice list” and “On the nice list.” |
| Reason: The kit described above does meet the requirements of a set. The essential character of this set is the pad of lined, decorative paper, which serves as the focal point on which the other items are used. |
| Ruling Date: March 6, 2025 |