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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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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.

N342622: The tariff classification of plain-woven polyester upholstery fabric from China

HTS: 5512.19.0040, 9903.01.24, 9903.88.03, 13.6% + 20% + 25%, “Woven fabrics of synthetic staple fibers, containing 85 percent or more by weight of synthetic staple fibers: Containing 85 percent or more by weight of polyester staple fibers: Other: Other: duck.”
Item: Flexsteel Pattern 021 (Rosecourt) is a printed fabric of plain weave construction. The fabric weighs 333.1 g/m2 and is composed of 95.8% polyester staple fibers and 4.2 percent linen staple fibers. The fabric contains 10 warp ends per one centimeter and 11 filling picks per one centimeter. Additionally, the fabric contains 3 ply yarns in both the warp and filling direction. The average yarn number for this fabric has been calculated to be 18.9 in the metric system. A plastic type coating has been applied to the reverse side of the fabric; however, the coating is not visible to the naked eye. This fabric will be imported in 55-inch widths and will be used for upholstery.
Reason: N/A
Ruling Date: March 20, 2025

N346307: The tariff classification of an air conditioning system from Canada

HTS: 8415.20.0000, 9903.01.10, 1.4% + 25%, “Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and humidity, including those machines in which the humidity cannot be separately regulated; parts thereof: Of a kind used for persons, in motor vehicles.”
Item: The item in question is a Heating, Ventilation, and Air Conditioning (HVAC) system. The HVAC system consists of various items that together regulate temperature and humidity within the cabin of an all-terrain vehicle. The items, which are packaged together ready for retail sale, consist of an evaporator, a condenser, a compressor, a heater, a control panel assembly, and three specifically configured refrigerant hose assemblies that connect these components to each other.
Reason: N/A
Ruling Date: March 20, 2025

N346345: The tariff classification of the Genotizer 20K Well Chip and the D_PCR Chip Case from South Korea

HTS: 3926.90.9910, 5.3%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Laboratory ware.” (D_PCR Chip Case) 9027.90.5650, free, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Microtomes; parts and accessories: Parts and accessories: Of electrical instruments and apparatus: Other”
Item: The first item under consideration is described as the Genotizer 20K Well Chip. The chip is made of plastic and contains an array of over 20,000 microwells and is used with a Lab On An Array (LOAA) analyzer or an LOAA-M System for detection and quantification of nucleic acid targets. The chip also includes an Electrically Erasable Programmable Read-Only Memory (EEPROM) element for storing specimen identification (barcode information). The memory is not capable of storing any information other than the specimen identification and is not required to be used for a run on the analysis machine. The primary function of the chip is to securely hold the polymerase chain reaction (PCR) mixture, however, it is imported empty. Each chip is single use only and is then discarded. The second item under consideration is described as the D_PCR Chip Case. The round, clamshell-style case is approximately 2 inches in diameter and holds the Genotizer 20K Well Chip in place on the analyzer. The chip case also contains a heating element (thermal cycler) and a fluorescent sensor, along with an electronic control system that connects to the EEPROM element of the chip and the analyzer.
Reason: The subject D_PCR Chip Case is an accessory that can only be used with the LOAA On-Point and LOAA-M On-Point Instruments. Further, the instruments also require a certain type of case that has the associated connections available with the D_PCR Chip case. On the other hand, the chip is solely used to store the PCR mixture and go into the case. Any chip of roughly the size and shape of the Genotizer 20K Well Chip would be suitable. It is predominately made of plastic and does not have any features that make it solely useable with the case or the analyzer. Therefore, the Genotizer 20K Well Chip is not considered an accessory.
Ruling Date: March 20, 2025

N346365: The tariff classification of a gear shift boot and a transmission shift lock from Mexico

HTS: (Gear shift boot) 8708.99.8180, 9903.01.01, 2.5% + 25%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” (Transmission shift lock) 8708.99.6890, 9903.01.01, 2.5% + 25%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other parts for power trains: Other.”
Item: The articles under consideration are a Gear Shift Boot and Transmission Shift Lock. The gear shift boot is used to cover the gear shifter lever in a passenger vehicle to protect it from dust, dirt, and debris while providing an aesthetically pleasing interior appearance. The gear shift boot is made with vinyl to simulate real leather. The transmission shift lock is a component within a gear selector mechanism that prevents the gear lever from being unintentionally shifting out of the “park” position. This is a safety feature on passenger vehicles with automatic transmissions to prevent accidental gear changes. The driver can select the desired gear by engaging the brake pedal to unlock the shift lock.
Reason: N/A
Ruling Date: March 20, 2025

N346483: The tariff classification of bangle set from China

HTS: 7117.19.9000, 9903.88.15, 11% + 7.5%, “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other: Other”
Item: The item is comprised of a set of three bangle bracelets held together with a cable chain. The bracelet components include: two 2.6 mm *2.5 brass wire, 1 Lauren zinc logo tag, one 1.5 brass cable chain, one 6mm brass bead, twelve 3mm brass balls and one 7mm acetate bangle. The bangles will be packaged in a blister card and sold as a set.
Reason: The base metal components predominate in both value and quantity. Accordingly, the base metal imparts the essential character.
Ruling Date: March 20, 2025

N346520: The tariff classification of a garland from China

HTS: 4420.19.0000, 3.2%, “statuettes and other ornaments, of wood, other than tropical wood.”
Item: The item under consideration, “valentine foam heart and bead garland,” is intended to be used as decoration in the home. The garland is constructed of foam hearts and wooden beads (Maple wood) strung on hemp rope with a ribbon and hemp rope tassel at each end. The garland features two pink, two red and two purple foam hearts and twelve white, eight red and eight pink wooden beads. The item is available in different colors. The garland measures approximately 30 inches in length.
Reason: N/A
Ruling Date: March 20, 2025

N346733: The tariff classification of clothes hangers from China

HTS: 4421.10.0000, 9903.01.24, 3.2% + 20%, “Other articles of wood: Clothes hangers.”
Item: Item 1 is a hanger designed to hold both an upper body garment and a lower body garment simultaneously, for example a suit jacket and pants. The hanger is made primarily of wood with a top section that slopes down on each side and is notched near each end, and a metal top hook. Suspended with metal fasteners across the bottom is a wooden rod to fold pants over. The wood portions make up approximately 75% of the cost and weight of the finished hanger. Item 2 is a hanger designed to hold pants. A wooden horizontal cross piece with a wire top hook suspends a parallel wooden rod a couple of inches below. Metal wire connects the pieces. The wooden elements make up approximately 70% of the cost and weight of the finished hanger. Item 3 is a hanger designed to hold both an upper body garment and a lower body garment simultaneously. As with Item 1, the hanger is made of a wooden top portion that slopes down on each side and is notched near the ends. A horizonal metal bar with two metal clips is attached below to clip a skirt or pants. The wood accounts for approximately 65% of the cost and weight of the finished hanger. Item 4 consists of a wooden horizontal cross piece with a wire top hook. A metal wire is attached that runs parallel to the wooden piece a couple of inches below and has two metal clips attached to hold a skirt or pants. The wooden elements make up approximately 50% of the cost and 55% of the weight of the finished hangers. The remainder of the cost and weight is the metal components. Item 5 resembles Item 4, except the clips are plastic. The wood makes up approximately 55% of the cost and weight of the finished hanger, the metal makes up approximately 25%, and the plastic makes up the remaining 20%.
Reason: In the case of Items 1, 2, and 3, the wood is the most essential component in terms of role and also predominates by weight and cost. For Item 4, the wood again predominates by weight and plays an indispensable part in the construction of the hanger. The wood, therefore, imparts the essential character. For Item 5, the roles of the materials are more equal, but, as the wood predominates by cost and weight, the wood imparts the essential character.
Ruling Date: March 20, 2025

N346795: The tariff classification of a tactical laser light from China

HTS: 9013.80.9100, 9903.01.24, 9903.88.15, 4.5% + 20% + 7.5%, “Liquid crystal devices not constituting articles provided for more specifically in other headings; lasers, other than laser diodes; other optical appliances and instruments, not specified or included elsewhere in this chapter; parts and accessories thereof: Other devices, appliances and instruments: Other.”
Item: The subject light is a handheld laser light source with optional LED light used primarily by first responders in environments where smoke and fire are present. The unit consists of a motherboard and processor enclosed within a housing. At the top of the housing is the laser and LED light source. The device is powered by a rechargeable battery. When the user finds themselves in a smoke-filled environment, they initiate the device, which projects a laser grid. This grid creates a reference plane, which illuminates the smoke and allows the user to track smoke flow, density, and source. Additionally, the lasers will bounce off walls and other obstacles, including other individuals, in the immediate area, allowing the user to better navigate their environment. In addition to the lasers, the optional LED light can be used as an additional light source.
Reason: N/A
Ruling Date: March 20, 2025

N346848: The tariff classification a textile costume trunk 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: The Dress-Up Time Daniel Tiger Trunk, which consists of costume kit with flimsy pieces to dress up as Daniel Tiger and his friends Katerina, Owl and Prince Wednesday. The first piece referred to as a Daniel Hat consists of a flimsy, man-made textile headpiece with large, loose, visible overlocked edges and is closed with a small patch of hook and loop fastener. The Daniel Hoodie is a flimsy hooded, man-made knitted textile top with large loose, visible overlock stitching and three small tabs of hook and loop fastener in front. Katerina’s Headband is a headpiece with cat ears and a bow. Katerina’s Skirt is a flimsy, man-made woven textile skirt with large, loose, visible overlock stitching. Although the skirt has a covered tunnel elastic waist, the skirt is not well-made. The elastic rolls and is not secured within the tunnel. The Prince Wednesday Crown is a man-made textile crown stitched with large, loose overlock stitching and an exposed elastic back strap. The Prince Wednesday Cape, is a flimsy, man-made woven textile cape, stitched with large, loose, visible overlock stitching and closed with a small patch of hook and loop fastener. The Owl Mask is a soft plastic eye mask with an exposed elastic back strap.
Reason: All the costume items meet the flimsy and non-durable requirements for classification within Heading 9505.
Ruling Date: March 20, 2025

N346883: The tariff classification of Christmas decorations 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 Cmas Lit Up Gingerbread Houses, which consists of an assortment of three styles of battery-powered, illuminated tabletop decorations, depicting classic Christmas gingerbread houses. The three plastic houses are styled in the traditional way, decorated with plastic Christmas wreaths, candy canes, snowy “icing” on the roof, peppermints, a gingerbread man and sprinkled with glitter to look like sugar. All three are different style houses, the first one is a two-story house measuring approximately 6” (L) x 2.75” (W) x 6.75(H), the second house is also a two-story house with arched windows, measuring approximately 5” (L) x 2.375” (W) x 6.5” (H) and the last is a cottage-style house measuring 6” (L) x 2.75” (W) x 6.75” (H). When activated, the windows are illuminated. The houses, sold separately, are marketed and sold exclusively as decorations for Christmas.
Reason: N/A
Ruling Date: March 20, 2025