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:
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
N346708: The tariff classification of a Halloween decoration from China
| HTS: 9505.90.6000, 9903.01.24, free + 20%, “Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Other: Other.” |
| Item: An item identified as Animated Broom, which consists of an animated, battery-powered witch broom decoration that when the sensor is triggered, appears to sweep by itself playing creepy music and making sweeping noises. The freestanding broom decoration is made predominantly of plastic and measures approximately 10.47”(L) x 10.47” (W) x 37.99” (H). The Animated Broom decoration will be marketed and sold as part of the Spooky Village Collection only for Halloween. |
| Reason: N/A |
| Ruling Date: March 18, 2025 |
N346168: The country of origin of Main Beam Module Assemblies from Mexico
| Origin: South Korea |
| Item: There are fourteen (14) manufacturing steps that take place in South Korea and Mexico. OS and LED driver firmware are downloaded to eMMC (AP) using the Gang Programming method, followed by data integrity verification. Marks product information by printing a 2D barcode with a UV Laser, ensuring production traceability. Prints solder paste onto printed circuit board (“PCB”) Pads with controlled pressure and speed to prepare for electronic component mounting. PCB Pad: a metal contact point on the PCB board that connects electronic components.Ensure quality by measuring the solder printing condition and deposition volume on PCB pads using 3D inspection. High-speed and precise placement of SMD components on the PCB for the SMT process implementation. Melting and curing the solder through temperature control by zone to permanently attaching SMD components to the PCB. Inspection of soldering quality and improper placement through automatic optical inspection to identify defects. Integrated ICT/FCT (Korea) Check for circuit abnormalities through ICT inspection, followed by software download and Secure Debug FCT testing. Apply coating liquid uniformly on the PCB substrate to protect it from moisture and contamination. Perform automatic optical inspection to check the mounting condition of the Waveless-type connector and automatically inspect the coated areas and thickness to confirm the coating status. Manufacturing process of Light Source Module in SL ELECTRONICS Router Process: Cut the PCB substrate into individual modules(Routing) and load them onto trays. Selective Soldering: Selectively solder components such as capacitors. Finally, export the finished light source modules to the SL Mexico factory Final Assembly Process at SL’s facility (Mexico) Assembling LAM, heat sink, bezel, lens and wiring (Assembly equipment). Conducting appearance and lighting inspection (Inspection equipment). Storing and sealing in a dedicated packaging container Shipping finished products from SL MEXICO to SL TENNESSEE (U.S). |
| Reason: For the Main Beam Module Assembly, the assembly of the Korean and Mexican origin LEDs and the Korean origin PCBAs in Mexico does not result in a substantial transformation. The processes performed in South Korea are sufficiently complex and meaningful so as to result in a substantial transformation of the underlying components. The processing and manufacturing of components in Korea, which consists of assembling components together with screws, connectors, and soldering, is sufficient to amount to a substantial transformation of the PCBA with LED lights. While the plastic lenses and reflector contribute to the car lamps ability to diffuse the light in accordance with customer expectations, as in HQ H114395, the PCBA is already a complete light source with a fully integrated LED and circuitry. The processes occurring in Mexico are minor and do not change the shape or material composition of the component parts. The parts still retain their names once assembly is complete. Therefore, the country of origin of the LED vehicle lamps is South Korea, where the PCBA with LED lights is manufactured, and Section 301 measures will not apply. |
| Ruling Date: March 17, 2025 |
N346169: The country of origin of a fuel injector
| Origin: Thailand |
| Item: The product in question is a fuel injector. The fuel injector is a solenoid valve that consists of a body that primarily encases a ball valve, a valve seat, an orifice plate, and a spring. The solenoid valve controls the flow of fuel into the fuel supply system of a motor vehicle. The injector is designed to connect to a fuel rail and an intake manifold. Concerning the origin of the fuel injector, it will be assembled in Thailand from components that originate in Japan, Thailand, and China. The following processes occur in Thailand prior to the final assembly. A hole is drilled into the circular shaped plate to create a plate with an orifice. Less than 5% of material is removed. To produce the solenoid actuator, pins manufactured in China are connected to wires and inserted into a Thai-manufactured bobbin. The necessary winding process occurs. The components are then welded in place. To produce a valve subassembly, a ball of Japanese origin is welded to a Thai-manufactured armature. The ball is then subjected to a grinding process. Afterward, a filter, which is of Chinese origin, is positioned in place. The final assembly process begins with the installation of a Thai magnetic ring and a Chinese adjust tube into a core produced in Thailand. Then, an inlet tube, a non-magnetic tube and a guide tube, all from Thailand, are connected and welded to the core. Next, a solenoid, along with a magnetic cap and ring, which are both manufactured in Thailand, are installed to the core and welded in place. A plastic piece produced in Thailand is placed over the solenoid. Afterwards, an orifice plate is welded to a Thai-manufactured valve seat and these connected components are installed into the housing. Additional components are then installed into the housing, which includes the valve subassembly and a Chinese spring. Once these components are adjusted, they are welded into position. Upon completion, the finished fuel injector undergoes various testing. |
| Reason: In this instance, components from Japan, China and Thailand are assembled together in Thailand to form subassemblies that are affixed to additional components from China and Thailand to produce a fuel injector. When considering the totality of the circumstances of the fuel injector, the manufacturing of the valve body, along with the assembly processes that join a Thai-produced solenoid and the valve subassembly to the body, in Thailand, taken as a whole, 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. The country of origin of the fuel injector is Thailand. |
| Ruling Date: March 17, 2025 |
N346378: The country of origin of a double flanged wheel hub unit with roller bearings
| Origin: Thailand |
| Item: The article under consideration is a double flanged wheel hub unit incorporating tapered roller bearings, which is used in passenger vehicles. The assembly features an outer flange and an inner flange, which work together to support the wheel and axle connection. The outer flange is typically bolted to the wheel, providing a secure mounting point, while the inner flange connects to the axle, via a splined interface for torque transmission. Between the flanges, the rotating body, which includes the tapered roller bearings, allows for low-friction rotation of the wheel. The assembly also integrates an anti-lock braking system (ABS) sensor, which monitors wheel speed for anti-lock braking functionality. The outer and inner flanges are made in Thailand, while the rest of the components are made in China and imported into Thailand for final assembly. In Thailand, the outer flange is made from a metal rod and undergoes cutting, forging, normalizing, rough machining, shot blasting, turning, heat treating, turning again, drilling, milling, grinding the surface and outer diameter, grinding raceway, and superfine grinding. The inner flange is made from a metal rod and undergoes cutting, hot forging, normalizing, rough machining, shot blasting, turning, heat treatment, turning again, drilling, splining, grinding raceway, and superfine grinding. Next, the Chinese bolts are pressed into the inner flange, rollers are installed into the inner flange, grease is added, all components are combined together, and ABS sensor is installed. Finally, the product is cold formed, laser marked, sprayed with anti-rust oil, and packaged ready for shipment to the United States. |
| Reason: The outer and inner flanges are the dominant components that impart the character of the double flanged wheel hub at issue. Therefore, the country of origin of the double flanged wheel hub unit incorporating tapered roller bearings will be Thailand. |
| Ruling Date: March 17, 2025 |
N346462: The tariff classification and country of origin of teacher planners
| HTS: 4820.10.4000, free, “Registers, account books, notebooks, order books, receipt books, letter pads, memorandum pads, diaries and similar articles: Other.” |
| Origin: Vietnam |
| Item: Two teacher planners containing approximately 200 pages ring-bound between rigid covers. The covers are composed of a greyboard inner core covered with polyurethane (PU) sheeting. Inside, bound on the rings (the rings do not open), are the following features: a pocket page made of polypropylene (PP) plastic; a plastic 10-inch ruler; a page of useful stickers for the teacher to annotate pages in the planner; a page listing holidays and other special dates; grid pages for recording seating charts; an absentee/tardiness log; pages for monthly overview notes; a grid calendar page for each month; daily dated pages for lesson plans; grade recordation pages; parent/student contracts; field trip planner pages; a one-page map of the United States; and several lined pages for general notes. Each section is tabbed. The planner also includes an elastic pen loop and an elastic band closure. The outer dimensions of the notebook are approximately 9.5” x 11.5” with 8.5” x 11” pages. |
| Reason: For the planners, many of the key raw materials, including the paper and greyboard, are made in Vietnam. The key step of printing the pages occurs in Vietnam. Indeed, the essence of the finished planners are the printed pages. The bulk of the manufacturing and assembly of the final planners occurs in Vietnam. The covers may protect and organize the pages, but it is the printed pages that render the planner useful for its intended purpose. Considering the totality of the materials and manufacturing, the country of origin of the planners is Vietnam. |
| Ruling Date: March 17, 2025 |
N346508: Classification and country of origin determination for scarves; 19 CFR 102.21(c)(2); tariff shift
| HTS: 6214.10.1000, 9903.88.15, 9903.01.24, 1.2% + 7.5% + 20%, “Shawls, scarves, mufflers, mantillas, veils and the like: Of silk or silk waste: Containing 70 percent or more by weight of silk or silk waste.” |
| Origin: China |
| Item: The goods are scarves constructed from 100% woven silk fabric. The dimensions of the scarves will be 65 centimeters by 65 centimeters, and the manufacturing operations will be as follows: 100% woven silk fabric will be woven from silk yarns, printed, and dyed in China. The fabric is then sent on rolls to Cambodia where it will be cut to shape and sewn into silk scarves. After the scarves are finished, they are tagged with the price and country of origin and then sealed in individual plastic bags, packed in cartons, and shipped directly to the United States. |
| Reason: The manufacturing operation in China will start with silk yarns, which will be woven together to create a textile fabric, thus meeting the definition of a fabric-making process. Therefore, the country of origin of the scarves is China. |
| Ruling Date: March 17, 2025 |
N346644: The tariff classification and country of origin of a ring binder
| HTS: 4820.30.0020, free, “Binders (other than book covers), folders and file covers: Looseleaf binders.” |
| Origin: China |
| Item: The item under consideration is a ring binder, measuring approximately 10.4” x 11.3” x 1.7”(D) The outer cover is constructed of a greyboard core covered completely with polypropylene (PP) sheeting. Mounted on the inside spine is a metal three-ring binder mechanism. The binder features one exterior pocket and two interior pockets.The metal binder mechanism and the binder cover are manufactured in China. The two subcomponents are then shipped to Vietnam where the metal binder mechanism will be riveted to the interior spine of the binder cover by an automated process to complete the binder. The binders are then packaged for shipment to the United States. |
| Reason: The processes performed in Vietnam do not result in a substantial transformation. The combining of the cover with the binder mechanism involves a simple assembly operation, riveting, which does not involve a significant investment in time, complex machinery, or technical skill. The country of origin of the finished ring binder is China, the country in which the cover and binder mechanism were manufactured. |
| Ruling Date: March 17, 2025 |
N346041: The tariff classification of three travel document holders from China
| HTS: 4202.92.9100, 9903.88.03, 9903.01.24, 17.6% + 25% + 20%, “other containers and cases, with outer surface of sheeting of plastic or of textile materials, other, other, with outer surface of textile materials, of man-made fibers (except jewelry boxes of a kind normally sold at retail with their contents).” |
| Item: The three articles are travel document holders. They are designed to provide storage, protection, portability and organization to a passport, boarding pass, identification, and other travel documents. Each article is constructed with an outer surface of polyester, which is a man-made textile material. Each article features one adjustable neck strap. |
| Reason: N/A |
| Ruling Date: March 14, 2025 |
N346243: The tariff classification and country of origin determination for laparotomy sponges; 19 CFR 102.21(c)(2)
| HTS: 6307.90.9891, 7%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Origin: Vietnam |
| Item: The samples, “laparotomy sponges,” are disposable textile pads designed to cover wounds and absorb bodily fluids during medical procedures. The sponges are composed of 100% woven cotton fabric. Each sponge consists of four fabric layers formed from one large piece of folded fabric. The folded fabric is hemmed on all sides. The sponges feature a 4 inch long barium sulfate monofilament strip inserted into each sponge to facilitate X-ray detection to help prevent the item from being left in the patient’s body, and a 12 ½ inch long 100 percent cotton dyed blue woven loop carrying strap sewn to one corner for easy removal of the sponge out of a patient’s body during surgery. The sponges are available in the following sizes: 2 inches by 2 inches, 12 ply or 8 ply; 3 inches by 3 inches, 8 ply; 4 inches by 4 inches, 8 ply, 12 ply, 16 ply, or 32 ply; 8 inches by 4 inches 12 ply, 16 ply, or 24 ply. Sponges of equal size and style will be imported banded together in groups of five. They will be imported into the United States in a carton containing 800 sponges and sold directly to U.S. medical and healthcare supply companies. |
| Reason: As the laparotomy sponges are comprised of fabric that is formed by a fabric-making process in a single country, that is Vietnam, as per the terms of the tariff shift requirement country of origin is conferred in Vietnam. |
| Ruling Date: March 14, 2025 |
N346314: The classification of a comforter from China
| HTS: 9404.40.9022, 9903.01.24, 12.8% + 20%, Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Quilts, bedspreads, eiderdowns and duvets (comforters): Other: With outer shell of man-made fibers |
| Item: The subject article is identified as the JLA Home Down Alternative Comforter. It is a queen-size comforter, measuring 90" x 90", with an outer shell of 100% polyester woven fabric and a stuffing of 100% polyester fiberfill. The quilting boxes measure approximately 15" x 15”. The top and bottom edges are finished in a knife edge and the lateral edges are folded under and hemmed. The front face features a white floral print on a beige background and the back is an off-white solid. The comforter is made in China. |
| Reason: N/A |
| Ruling Date: March 14, 2025 |