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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N346763: The tariff classification of the Driving Board from China
| HTS: 8537.10.9170, 9903.88.03, 9903.01.24, 2.7% + 25% + 20%, “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other” |
| Item: The merchandise under consideration is identified as the Driving Board, which is a printed circuit board assembly with three connectors, capacitors, diodes, integrated circuits, and a fuse, that functions to electrically connect a liquid crystal module to two relay boards. |
| Reason: N/A |
| Ruling Date: March 26, 2025 |
N346764: The tariff classification of the “Bunch-O-Balloons Summer Water Party Pack” from China
| HTS: (balloons) 9503.00.0013, free, “Tricycles, scooters, pedal cars and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Inflatable toy balls, balloons …: Labeled or determined by importer as intended for use by persons: 3 to 12 years of age.” (water slide mat) 9503.00.0073, 9903.01.24, free + 20%, “Tricycles, scooters, pedal cars, and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended for use by persons: 3 to 12 years of age.” |
| Item: The party pack consists of the following items: Six “Bunch-O-Balloons Tropical Party Stems” (35 balloons per stem/210 multi-colored balloons total) Two “XSHOT Water Fast-Fill Blasters” (water guns) One “Bunch-O-Balloons Water Slide Wipeout” (water slide mat) The “Bunch-O-Balloons Tropical Party Stems” consist of 6 stems with each stem having 35 multi-colored latex balloons. Each balloon is attached to an individual plastic tube that is secured on to a onetime use, self-sealing, water hose adapter nozzle located at the end of a stem. The nozzle is designed for attachment to a water source such as a spigot or faucet. |
| Reason: N/A |
| Ruling Date: March 26, 2025 |
N346820: The tariff classification of an Ortho Workstation Immunohematology Analyzer from the United States
| HTS: 8421.19.0000, 1.3%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Centrifuges, including centrifugal dryers: Other.” |
| Item: The item under consideration is the Ortho Workstation Immunohematology Analyzer, which is a combined 2-in-1 blood testing system providing both incubation and centrifugation in one machine. Despite being called an analyzer, the device itself does not perform any analyzing function and instead solely performs the incubation (keeping the specimen at a controlled temperature) and centrifugation (performing the separation of the specimen). |
| Reason: In this case, both the centrifuge function and the incubator function are of equal merit. Thus, the two headings which merit equal consideration are heading 8421, which provides for the centrifuge for separating the specimen and heading 8419, HTSUS, which provides for the incubator (keeping the specimen at a controlled temperature). As there is no one principal function, the Ortho Workstation Immunohematology Analyzer is classifiable in accordance with GRI 3 (c), which is the last heading from among those that equally merit consideration, i.e., heading 8421. |
| Ruling Date: March 26, 2025 |
N346904: The country of origin of facial tissue
| Origin: Indonesia |
| Item: The paper products under consideration are packages of "facial tissue." They come in a variety of plies (single, double, and triple) and 1/2 fold. The bulk rolls of facial tissue stock are manufactured in Indonesia. The paper is White/Kraft paper: virgin; layer: 1-3; 11-20 g/sm. These parent rolls of tissue paper, which measure in multiple widths from 150mm up to 250mm and have a maximum roll diameter 250mm, are then sent to China, where the tissue paper is embossed, folded into sheets, and cut to size. The finished facial tissues are then subjected to quality control and packaged. |
| Reason: In China the facial tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, folding, cutting, and packaging. The country of origin of the finished facial tissue is Indonesia. |
| Ruling Date: March 26, 2025 |
N346906: The country of origin of toilet tissue
| Origin: Indonesia |
| Item: The paper products under consideration are packages of "regular toilet tissue" and "jumbo toilet tissue." They come in a variety of plies (single, double, and triple). The bulk rolls of toilet tissue stock are manufactured in Indonesia. The paper is White/Kraft paper: virgin; layer: 1-2; 12-18 g/sm. These parent rolls of tissue paper, which measure in multiple widths from 2750mm up to 2800mm and have a maximum roll diameter 2800mm, are then sent to China, where the tissue paper is embossed, rewound, cut to size, subjected to quality control, and packaged. |
| Reason: In China the facial tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, folding, cutting, and packaging. The country of origin of the finished facial tissue is Indonesia. |
| Ruling Date: March 26, 2025 |
N346908: The country of origin of toilet seat covers
| Origin: Indonesia |
| Item: The paper products under consideration are toilet seat covers. The bulk rolls of toilet seat covers are manufactured in Indonesia. The toilet seat covers are White/Kraft paper: virgin; layer: 1;12-18 g/sm. These parent rolls of toilet seat covers, which measure 380mm in width and have a maximum roll diameter 380mm, are then sent to China, where the tissue paper is embossed, folded, cut to size, subjected to quality control, and packaged. |
| Reason: In China the tissue paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, folding, cutting, and packaging. The country of origin of the finished toilet seat covers is Indonesia. |
| Ruling Date: March 26, 2025 |
N346272: The country of origin of a glass screen protector
| Origin: Thailand |
| Item: A glass screen protector for the iPhone 15 Pro Max cell phone. The glass screen protector consists of the following components: clear glass from China, a plastic tray from Thailand, a screen protector installation kit from China (which includes cleaning wipes, an instruction manual, a dust removal sticker, a squeegee, and a microfiber cloth), and AB glue from China. The glass screen protector is applied to a smart phone screen to provide a protective barrier against scratches and normal wear and tear. The screen protector will be sold in retail and online stores to create a finished glass screen protector for smart phones. The glass screen protector is tempered. The glass screen protectors will be manufactured and assembled with other components in Thailand to form complete glass screen protector kits prior to importation into the United States. The raw glass (sourced from China) is shipped to Thailand for manufacturing. The production process in Thailand includes die cutting, CNC machining, polishing, cleaning, tempering, lamination, and tray injection. |
| Reason: The processes applied to the glass in Thailand, including the die cutting, toughening (tempering), and application of AB glue from China, change the name, character and use of the material and thus substantially transforms it into a new and different article, toughened (tempered) glass classified in subheading 7007.19. Accordingly, the country of origin for the glass screen protector is Thailand. |
| Ruling Date: March 25, 2025 |
N346321: The tariff classification of a child’s fanny pack from China
| HTS: 4202.92.3131, 9903.88.03, 9903.01.24, 17.6% + 25% + 20%, “travel, sports, and similar bags, with outer surface of textile material, other, other, of man-made fibers.” |
| Item: The article, referred to as the “Polyester Halloween pumpkin shape bag with ghost face,” is a child’s fanny pack constructed of 100% polyester, which is a man-made material. It is designed to be worn around the waist for hands-free storage of personal effects during sport activities and travel. It also provides protection, portability, and organization to a child’s personal effects such as snacks, supplies and candy. The article has a top zippered closure and one adjustable textile strap. It measures approximately 9.5 inches (L) by 3.5 inches (W) by 7 inches (H). |
| Reason: N/A |
| Ruling Date: March 25, 2025 |
N346370: The tariff classification of footwear from China
| HTS: 6405.90.9060, 9903.01.24, 12.5% + 20%, “Other footwear: Other: Other: Other.” |
| Item: A casual shoe made with identical uppers and five different outsoles. The women’s shoes are closed-toe, closed-heel, below-the-ankle, casual, slip-on shoes with foxing or foxing-like bands. The upper of each shoe style is made of 100% polyurethane with elastic gore on either side of the vamp and a padded collar. The upper will be combined with five different outsoles, all made of thermoplastic rubber (TPR) with leather flocking covering a majority of the surface area in contact with the ground. The leather flocking on the five outer soles measures from 0.25 millimeters to 1.25 millimeters thick. The FOB value provided for each style is over $12 per pair. |
| Reason: N/A |
| Ruling Date: March 25, 2025 |
N346397: The country of origin of an air fryer
| Origin: Vietnam |
| Item: The product under consideration is the “MVN Air Fryer VIII.” This air fryer is a domestic electric countertop device that cooks food by circulating hot air around the ingredients using fan blades. The air fryer is manufactured in Vietnam through a three-stage process. The first stage involves three phases: Phase One involves the production of the structural body and other plastic components (e.g., the bottom cover, motor cover, power box, heat insulation block, internal base plate bracket, injection molded upper housing, injection molded lower housing, ring rail, injection molded front bucket cover, air outlet window, control panel bracket, left and right windshield brackets) by an injection molding process. The plastic raw materials are sourced from Vietnam, Thailand, Cambodia, and China. Phase Two involves the production of the metal parts, including the internal base plate, sheet metal upper housing and lower housing, edge trim (or surrounding wall), reflecting cover and sheet metal front bucket cover from steel coiled materials. The fabrication will be completed in Vietnam from steel sourced from either Vietnam or China. Phase Three involves the production of the heating pipe or heating element is manufactured by a third-party supplier of MVN in Vietnam from various raw materials.In the next stage, the display and power boards are manufactured by a third-party supplier in Vietnam from various raw materials. In the final stage, also performed in Vietnam, the Vietnamese-origin body and other plastic and metal components will be placed with the remaining components originating from Vietnam, China, and Thailand on the main assembly line to produce subassemblies (e.g., the bucket and base subassemblies) followed by final assembly of the finished MVN Air Fryer VIII. It will then be tested, inspected, and packaged. |
| Reason: The Chinese components undergo processing, which is 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. In addition, essential parts are manufactured in Vietnam. Thus, the country of origin for the MVN Air Fryer VIII will be Vietnam. |
| Ruling Date: March 25, 2025 |