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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N346250: The country of origin of a fuel injector assembly
| Origin: Thailand |
| Item: The article under consideration is a fuel injector assembly, which is a component of the automotive fuel supply system. It is a solenoid valve that connects to the fuel rail and the intake manifold, and controls the fuel injection volume and injection timing. The fuel injector assembly consists of a fuel rail and eight fuel injectors connected to a fuel pass tube. The fuel injector armature and power group are made in Thailand, while the rest of the components are imported from China and Japan for further assembly. The body of the fuel rail, as well as the fuel pass tube and inlet press ring, are made in Thailand. The rest of the components of the fuel rail are made in China and imported to Thailand for further assembly. In Thailand, all components are combined together to create a complete fuel injector assembly. |
| Reason: The processes in Thailand substantially transform the individual components from China and Japan into the fuel injector assembly. These processes are sufficiently complex and meaningful as to result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of a new article, possessing a new name, character and use. Therefore, the country of origin for the fuel injector assembly will be Thailand. |
| Ruling Date: March 13, 2025 |
N346317: The country of origin of a power bank
| Origin: China |
| Item: The rechargeable lithium-ion power bank is a portable device with a maximum output of 10.5 W and a nominal capacity of 5,000 mAh. The device contains a single battery cell enclosed within a plastic housing with a battery level indicator, a micro-USB input port, a USB-C input and output port, and two USB-A output ports. It measures approximately 9.8 centimeters in length, 6.5 centimeters in width, and 1.6 centimeters in height.The assembly process occurs in Vietnam using components sourced exclusively from China and begins with the assembly of a printed circuit board assembly (PCBA) that incorporates USB functionality. The PCBA is assembled using surface-mount technology, a process that attaches circuit board components to the surface of a printed circuit board. The components added during this process include resistors, capacitors, integrated circuits, and various USB connectors. Next, a worker mounts the PCBA and a Chinese battery cell into the bottom shell of the housing, connects the PCBA to the battery, and installs the top shell. The completed power bank undergoes various types of testing, including charge testing and visual inspection. |
| Reason: The assembly operations that occur in Vietnam do not result in a substantial transformation. There is no change in the name, use, or character of the battery cell after the assembly process occurs. U.S. Customs and Border Protection has previously held that the assembly of battery cells into battery packs does not result in a substantial transformation of the battery cells because the essential character of the cells does not change simply by being placed together in a plastic housing. Here, the function of the battery cell is to store and provide power, and the function of the battery cell in the finished power bank is likewise to store and provide power. In view of these facts, and based on the totality of the circumstances, the country of origin of the subject power bank is China. |
| Ruling Date: March 13, 2025 |
N345959: The tariff classification of gloves from Sri Lanka
| HTS: (styles 18030 and 18031) 6216.00.5820, 10.4%, "Gloves, mittens and mitts: Other: Of man-made fibers: Other: With fourchettes: Other. (style CHN18001) 4203.29.3020, 14%: Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Other: Other: Other: Men’s: Lined." (style CHN18000) 4203.29.3010, 14%, "Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Other: Other: Other: Men’s: Not lined." (style CHN18011) 6116.91.0000, 31.2¢/kg + 7%, "Gloves, mittens and mitts, knitted or crocheted: Other: Of wool or fine animal hair." |
| Item: Style CHN18030 is a glove with an outer shell constructed of 100% polyester woven fabric except for the palm and backside fingertips fabric, which is stated to be a plastic-coated synthetic suede fabric constructed of 60% polyester and 40% polyurethane. Style CHN18031 is a glove with an outer shell constructed of 100% polyester woven fabric except for the palm and backside fingertips fabric, which is stated to be a plastic-coated synthetic suede fabric constructed of 60% polyester and 40% polyurethane. Style CHN18001 is a glove with an outer shell constructed of goat leather. Style CHN18000 is a glove with an outer shell constructed of goat leather. Style CHN18011 is a glove constructed of 100% merino wool knit fabric. |
| Reason: The essential character of Style CHN18030 is imparted by the non-woven fabric on the palm side from fingertips to wrist. The essential character of Style CHN18031 is imparted by the palm side non-woven fabric from fingertips to wrist. |
| Ruling Date: March 12, 2025 |
N345991: The country of origin of a thin-film transistor (TFT) liquid crystal display (LCD) module
| Origin: Japan |
| Item: The merchandise under consideration is a thin-film transistor (TFT) liquid crystal display (LCD) module, which is designed for integration into automotive systems for heads-up displays (HUDs). This display module includes a signal reception, inclusive of low voltage differential signaling (LVDS), a signal distribution to individual pixels, and an image display. The subject TFT-LCD module does not contain any video signal conversion capabilities.In Japan, the following steps occur. First, the process starts with a glass substrate, which entails multiple steps in the chemical vapor deposition machines to build a TFT array structure on the substrate. Then, the color filter is made on a matching and separate glass substrate. Next, the LCD panel is filled using a one drop fill (ODF) process, which is applied to the entire TFT array substrate. During this process, the liquid crystal material is compressed between the TFT array side, and the color filter glass substrate is added and aligned on top. This process creates a sheet of TFT-LCD cells that will later be cut into individual cells.In China, the substrate is cut into “chips” and assembled. The assembly entails taking the LCD cell (the "chip"), and affixing driver integrated circuits (ICs), polarizers, flexible printed circuit(s) (FPC(s)), a backlight, and the frame. Lastly, it goes through outgoing quality testing. |
| Reason: The completed TFT-LCD cells, regardless of where they are cut to size, are the dominant component that provides the character of the finished flat panel display modules. The complex manufacturing process performed in Japan renders the end-use of the cells predetermined, as they cannot be used for any other purpose than a display. Further, the cutting and assembly processes performed in China would not substantially transform the cells into new and different articles of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the country of origin of this TFT-LCD module is Japan. |
| Ruling Date: March 12, 2025 |
N345998: The tariff classification and country of origin of automotive floor mats
| HTS: 8708.29.5160, 2.5%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.” |
| Origin: Malaysia |
| Item: The article under consideration is a set of four polyvinyl chloride (PVC) automobile floor mats, which is designed to fit the contours of an automobile’s interior floor surface. The mats provide comprehensive coverage for the front and rear floor areas. The primary purpose of these mats is to protect the car’s flooring from dirt, moisture, and wear. They are also intended to enhance the overall interior appearance of vehicles.The PVC granules are purchased from China and imported to Malaysia for further processing. In Malaysia, the PVC granules are heated in an oven machine, then melted in a melting machine, and then finally molded into the pattern. |
| Reason: The PVC granules from China are substantially transformed in Malaysia into an identifiable article - automotive floor mat. As a result, the country of origin for the PVC automotive floor mats will be Malaysia for marking purposes. |
| Ruling Date: March 12, 2025 |
N346289: The country of origin of a cutting chisel
| Origin: Germany |
| Item: The merchandise under consideration is a cutting pick or chisel. The imported tool incorporates two parts: a cold forged steel body and a carbide tip. The chisel is used in underground coal mines on large continuous miner machines. It is the part of the machine that penetrates and cuts pieces of coal out of rock. Multiple chisels are used on one miner machine. In operation, each chisel is mounted into individual holders that are welded onto the drum of the continuous miner machine. Neither the steel body nor the carbide tip are reusable, and that once worn out they will be used as scrap. The manufacturing process for the chisel begins in China, where the steel body is cold forged. It is then sent to Germany, where the body is further machined. This includes machining a hole in the top of the body in order to accommodate the carbide tip. The base of the body is also further machined to specifications, and it is sandblasted and washed. Production of the carbide tip is done entirely in Germany, with raw materials that are put through specialized mixing and milling processes. Once mixed and milled, the carbide tip is pressed into a specific shape, sintered and sandblasted. The carbide tip is subsequently permanently soldered into the hole of the steel body, and the chisel is fully formed. The chisel is then heated up and cooled with oil, to increase the strength of the steel body. Finally, the finished chisel is sandblasted, washed and packaged for shipment. |
| Reason: The tool comprises two components, i.e., a steel body and a carbide tip. The steel body, while cold forged in China, undergoes significant machining in Germany. A hole is drilled into the top to accommodate the carbide tip. The base of the body is machined to exact specifications in order to fit into the holder on the continuous miner machine. The carbide tip is fully formed from raw materials in Germany through a specialized mixing and milling process. Additionally, the steel body and carbide tip are permanently brazed together in Germany. Considering the totality of the circumstances, the steel body and raw materials used to form the carbide tip undergo a substantial transformation in Germany. Accordingly, the country of origin for the finished chisel is Germany. |
| Ruling Date: March 12, 2025 |
N346297: The country of origin of an electric winch
| Origin: Thailand |
| Item: The subject winch is electrically powered and one model is equipped with a stainless-steel rope while the other uses a synthetic rope. Both models share the same specifications, including a maximum speed of 6 feet per minute at an 8000 pound capacity, and both are designed to be mounted on vehicles.The electric winch is assembled in Thailand and requires three primary subassemblies. They are identified as a Chinese-origin gearbox subassembly, a Thai-origin electric motor assembly, and a Thai-origin drum assembly. While the subject winch is currently manufactured in China, the manufacturing operations will move to Thailand by June of 2025 and both models will be assembled using the same operational production steps.The final assembly begins with preparing the motor assembly, a process that adds a waterproof ring, bearing, brake assembly, and brace shaft to the motor assembly. Following this, a worker seats a seal ring onto the Chinese gearbox before combining and fastening the gearbox to the motor assembly and drum assembly. The next series of steps are described as mounting a control box, connecting its wire harness, securing a rope to the barrel of the drum assembly, winding the rope around its circumference, and testing. Once the winch passes testing and inspection, it is packaged with various accessories including a handle remote, fairlead roller, and hook. |
| Reason: Based upon the manufacturing operations, the operational steps are not particularly complex. They consist of assembling a Chinese gearbox and other accompanying components with the core subassemblies (i.e., electric motor assembly and drum assembly) that are produced entirely in Thailand. Thus, based on the totality of the circumstances, the country of origin of the electric winch as described above, will be Thailand. |
| Ruling Date: March 12, 2025 |
N346306: The tariff classification of Shiitake Mushroom Spawn from China
| HTS: 0602.90.5000, 9903.01.24, 1.4¢/kg + 20%, “Other live plants (including their roots), cuttings and slips; mushroom spawn: Other: Other: Mushroom spawn.” |
| Item: The subject merchandise is Shiitake Mushroom Substrate. The product is composed of water, sawdust, bran, and shiitake mushroom spawn. The water, sawdust, and bran are combined and then pressed into a log, which is placed in a plastic bag with a filter and sterilized in an autoclave. Upon sterilization, a small amount of mushroom spawn is added to the log and incubated in a controlled environment for 1.5 - 3.0 months. Subsequently, the bag is removed to finalize the maturation process, and the log is placed in a cardboard carton with air holes and chilled for shipping. The log which weighs 1.6 - 1.8 kilograms is packed twelve to a carton for importation to the United States. The Shitake Mushroom Substrate is intended be used in commercial agriculture to produce mushrooms for consumption. |
| Reason: N/A |
| Ruling Date: March 12, 2025 |
N346309: The tariff classification of Mushroom Substrate from China
| HTS: 0602.90.5000, 9903.01.24, 1.4¢/kg + 20%, “Other live plants (including their roots), cuttings and slips; mushroom spawn: Other: Other: Mushroom spawn.” |
| Item: The subject merchandise is Mushroom Substrate Logs of two varieties. The first product is composed of water, sawdust, bran, and oyster mushroom spawn. The second product is composed of water, sawdust, bran, and lion’s mane mushroom spawn. Water, sawdust, and bran are combined and then pressed into logs, which are placed in plastic bags with a filter and sterilized in an autoclave. Upon completion of the sterilization process, small amounts of mushroom spawn are added to the sterilized logs and incubated in a controlled environment for 1.5 - 3.0 months to allow for maturity. Subsequently, the bags are removed to finalize the maturation process, and the logs are placed in a cardboard carton with air holes and chilled for shipping. The logs which weigh 1.35 - 1.45 kilograms are packed twelve to a carton or ten to a mesh bag for importation to the United States. The mushroom substrate logs are intended be used in commercial agriculture to produce mushrooms for consumption. |
| Reason: N/A |
| Ruling Date: March 12, 2025 |
N346315: The country of origin of a combination wrench
| Origin: Thailand |
| Item: The production process for the combination wrench begins in Thailand, where the wrench body is forged from Chinese-origin steel bar into its general shape and size. It is then trimmed and deburred. The wrench blank is then shipped to China where holes are punched, and the open-end and box-end are machined. The tool is further heat-treated, polished and electroplated. Finally, the wrench is packaged and shipped to the United States. |
| Reason: The forging of the steel imparts the essential characteristics of the finished wrench. In Thailand, the wrench is forged and takes on the general shape and size of the finished tool. The forged tool is not substantially changed so as to transform it into a new article with a different name, character or use. Therefore, the country of origin of the combination wrench is Thailand. |
| Ruling Date: March 12, 2025 |