Recent CBP NY Rulings

May 1, 2025 |Customs 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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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.

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N346219: The tariff classification of a plastic logo plate from China

HTS: 3926.90.9989, 9903.88.15, 9903.01.24, 5.3% + 7.5% + 20%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.”

Item: The product under consideration is an injection molded acrylonitrile butadiene styrene (ABS) plastic logo plate. This component is affixed to the rotating arm of the Quantum Automatic Wheelchair Securement Station and will feature the name of the company that manufactured the securement station, “Quantum.”

Reason: N/A

Ruling Date: March 18, 2025

N346291: The tariff classification of a beaded bag charm from China

HTS: 3926.90.3500, 9903.88.15, 9903.01.24, 6.5% + 15% + 20%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [b]eads, bugles and spangles, not strung (except temporarily) and not set; articles thereof, not elsewhere specified or included: [o]ther.”

Item: The product under consideration is a four-inch-long bag charm. It is intended to be attached to a bag strap by its metal clip. It features four decorations attached to the clip: a twisted polyester cord, two strands of plastic beads, and a flat polyester textile charm that is completely covered on the surface by glass and plastic beads and has the appearance of an avocado sliced in half.

Reason: N/A

Ruling Date: March 18, 2025

N346311: The tariff classification and eligibility of 9802.00.6000 of certain wood and self-tapping screws manufactured from raw materials in the United States and returned to the U.S. for further processing

HTS: 9802.00.6000, which provides a partial duty exemption for: [a]ny article of metal . . . manufactured in the United States or subject to a process of manufacture in the United States, if exported for further processing, and if the exported article as processed outside the United States, or the article which results from the processing outside the United States, is returned for the United States for further processing.

Item: The products to be imported are iron or steel wood screws and self-tapping screws that are produced in the U.S. at the OMG Building Products LLC manufacturing facility, in Agawam, Mass. OMG uses raw material wire coil and then cuts the wire to length, forms the head and drive system recess, pinches the point, and rolls the thread. The fasteners are then exported to Canada where they are hardened and tempered in electric heat-treating furnaces to improve their hardness and strength. The fasteners are then returned to the U.S. where they undergo the further process of electroplating to enhance their corrosion resistance and improve surface properties. Finally, the fasteners are packaged into a finished good to be sold to customers.

Reason: The wood and self-tapping screws are manufactured by OMG Building Products LLC, in Agawam, MA from wire coil. Manufacturing steps include cutting the wire to length, forming the head and drive system recess, pinching the point, and rolling the thread. These processing steps satisfy the second requirement that the metal must either be manufactured in the U.S. or subject to a process of manufacture in the U.S. The wood and self-tapping screws are then exported to Canada where they are hardened and tempered in electric heat-treating furnaces to improve their hardness and strength. This processing constitutes “further processed” under this tariff provision, satisfying the third requirement. The wood and self-tapping screws are then returned to the U.S. where they undergo the further process of electroplating to enhance their corrosion resistance and improve surface properties. Finally, the wood and self-tapping screws are packaged into a finished good to be sold to customers. The processing involved with electroplating of the screws constitutes “further processed” in the U.S., satisfying the fourth requirement.

Ruling Date: March 18, 2025

N346375: The country of origin of a double flanged wheel hub unit with ball bearings

Origin: Thailand

Item: The article under consideration is a double flanged wheel hub unit incorporating ball 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 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, balls are installed into the outer 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 for shipment to the United States.

Reason: In the instant case, the splining feature gives the wheel hub a functionality beyond a mere bearing. It allows the wheel hub to mesh with the drive axle to transmit torque. As such, 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 ball bearings will be Thailand.

Ruling Date: March 18, 2025

N346450: The tariff classification of footwear from China

HTS: 6404.19.9060, 9903.01.24, 9903.88.15, 9% + 20% + 7.5%, “footwear with outer soles of rubber, plastics, leather or composition leather and uppers of textile materials: other: other: valued over $12.00/pair: for women.”

Item: The woman’s boot is an above-the-ankle, below-the-knee, closed-toe/closed-heel fashion boot. It has a 2-inch-tall heel. The external surface of the upper is made of man-made textile fabric simulated to look like suede leather. The rubber/plastics outsole has textile flocking covering a majority of the external surface area in contact with the ground. It has no foxing or foxing-like band. The boot has a fabric lining in the shaft and a 7.5-inch-long functional slide fastener on the medial side. The FOB value per pair provided is over $12.00.

Reason: N/A

Ruling Date: March 18, 2025

N346570: The country of origin of a laptop

Origin: Vietnam

Item: The merchandise under consideration is the Notebook Computer, Model Aspire AG15-71P (Aspire), which is a laptop personal computer (PC) The motherboard PCBA is manufactured in Vietnam by the surface mounting of numerous components, such as integrated circuits, capacitors, diodes, resistors, etc. onto a bare printed circuit board. After the motherboard is manufactured, the Vietnam and/or Malaysian origin processor, the Taiwan and/or Korean origin memory, and the Taiwan origin SSD are inserted and mounted onto the motherboard where it is then is tested. Once testing is complete, the motherboard subassembly is shipped to China where the assembly of the Aspire laptop PC is completed by inserting the motherboard and various subassemblies of Chinese origin, such as the LCD display, the fan, the keyboard, the camera, the touchpad, the battery, and the antenna, into a housing by attaching cables, fastening with screws, arranging and alignment, and snap-fitting together to produce a functional automatic data processing machine.

Reason: Regarding the origin of the Aspire laptop PC, the assembly of the PCBA in Vietnam by soldering the individual components of various origins onto a bare printed circuit board results in a substantial transformation of those components to produce a motherboard of Vietnamese origin. Furthermore, the motherboard PCBA establishes the function of the Aspire laptop PC because it is the article within the assembly that houses and controls the interconnection of the processor CPU, memory, and contains the BIOS that enables the ADP machine to function. Lastly, the assembly work conducted in China by inserting, plugging, fastening, etc. does not substantially transform the motherboard PCBA into a new and different article. As a result of the forgoing, the Notebook Computer, Model Aspire AG15-71P, is considered a product of Vietnam for origin and marking purposes at time of importation into the United States.

Ruling Date: March 18, 2025

N346610: The tariff classification of an automatic dispensing machine from China

HTS: 8479.89.9599, 9903.88.03, 9903.01.24, 9903.85.08, 2.5% + 25% + 20% + 25%, “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.”

Item: The product in question is the Osmore dispensing machine. This freestanding, domed cylindrical device is intended to be placed on a table-top surface and is designed to dispense pre-packaged sealed mini cups, each containing a thin edible wafer and a drinkable liquid. It comprises of a housing that contains two electric motors, one to rotate the platform with 10 columns each holding up to 10 stacked mini cups, and the other to push the cups out onto a receiving platform. Affixed to the top of the dome is a small cross. To activate the dispenser, a user waves their hand within activation distance of the motion sensor that is positioned near the opening flap, causing the flap to open and the unit to dispense a single cup. The unit will be imported with a power cord, an OSMORE logo sticker, and a sticker depicting praying hands and a cross. The device is imported for use during church services to automatically dispense “communion hosts” and “wine” (grape juice). The OSMORE device will not be imported with the mini cups.

Reason: N/A

Ruling Date: March 18, 2025

N346687: The tariff classification of a Christmas decoration from China

HTS: 9505.10.2500, 9903.01.24, free + 20%, “Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Christmas ornaments: Other: Other.”

Item: An item identified as the Plastic Nutcracker with Light and Water movement. The battery-powered, illuminated decoration depicts the classic Christmas nutcracker king standing at attention attired in a golden crown, red jacket and black boots. When activated, the lighting illuminates the clear sections of the plastic figure, and the water is agitated, disbursing the glitter around inside the figure. The figure measures approximately 5"(L) x 4.25" (W) x 12.75" (H). The article will be marketed and sold only as a decoration for Christmas.

Reason: N/A

Ruling Date: March 18, 2025

N346688: The tariff classification of a nutcracker figure from China

Item: An item identified as Resin Flocking Nutcracker, which consists of an assortment of two nutcracker figures composed of polyresin and stone powder with the outer surface covered with polyester flocking. The figures depict a classic king nutcracker wearing a crown and holding a scepter. Both figures are the same except for color, one is blue and the other is purple. Each color is sold separately. The figures measures approximately 4.25”(L) x3”(W) x7.25”(H). The item will be marketed and sold as a decoration for Christmas.

Reason: N/A

Ruling Date: March 18, 2025

N346689: The tariff classification of Christmas decorations from China

Item: An item identified as Resin Nutcracker Decor, which consists of an assortment of two styles of nutcracker figures made of polyresin and natural stone powder. Each figure is standing on a circular base. The first figure depicts a traditional nutcracker king standing at attention attired in a jacket with epaulettes, high boots and a crown. On top of his crown, he is carrying a decorated Christmas tree with a golden star on top. The second figure depicts a traditional soldier nutcracker standing at attention also attired in a jacket with epaulettes and high boots. The soldier is balancing a tall stack of wrapped Christmas presents on his head. Each style is sold separately. The assortment of nutcracker decor figures is marketed and sold exclusively as Christmas decorations.

Reason: N/A

Ruling Date: March 18, 2025