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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N346398: The country of origin of an air fryer
| Origin: Vietnam |
| Item: The “MVN Air Fryer IX.” 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, which 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 Malaysia 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 IX. It will then be tested, inspected, and packaged. |
| Reason: The Chinese components undergo processing that 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 is Vietnam. |
| Ruling Date: March 26, 2025 |
N346408: The tariff classification of components for trash compactor bins from China
| HTS: (1) 7312.10.5000, 9903.81.90, 9903.01.24, free + 25% + 20%, “Stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: Stranded wire, ropes and cables: Stranded wire: Of stainless steel: Fitted with fittings or made up into articles.” (2, 3, 4, 5) 8479.90.8500, 9903.88.15, 9903.01.24, 9903.85.08, free + 7.5% + 20% + 25%, “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Of trash compactors: Other.” |
| Item: Five components for the cabinets of “smart” waste disposal and recycling bins, referred to as the Bigbelly Sense Max and Bigbelly Smart Max bins. The Bigbelly bins, which are not imported with the subject components, function as waste and/or recycling receptacles and are equipped with a sensor-activated, automatic compacting function. The bins are fully enclosed and will be situated in public places. Each of the five items will be imported individually for original equipment purposes. Part 1 is a stainless-steel front door release cable. Each end of the cable is fitted with stainless steel split rings. The cable is configured for the Bigbelly bins but could be used in other applications. The remaining items are specially shaped and designed for use solely with the Bigbelly bins. Part 2 is an aluminum foot pedal to open the chute for waste disposal or collection for recycling. Part 3 is a front door panel stamped out of galvannealed steel. Part 4 is a front door rain gutter that is stamped out of stainless steel. Part 5, the front door latch access plate, is a galvanized steel panel that prevents public access to the door lock hardware. The plate has an irregular shape and is custom designed to fit over the locking area. |
| Reason: N/A |
| Ruling Date: March 26, 2025 |
N346410: The tariff classification of Diclofenac Sodium Tablets in dosage form, from India
| HTS: 3004.90.9234, free, “Medicaments … consisting of mixed or unmixed products for therapeutic or prophylactic uses, put up in measured doses … or in forms or packings for retail sale: Other: Other: Other: Medicaments primarily affecting the central nervous system: Analgesics, antipyretics and nonhormonal anti-inflammatory agents: Other.” |
| Item: Diclofenac Sodium, imported in 25 mg, 50 mg and 75 mg tablets, is a nonsteroidal anti-inflammatory drug (NSAID). It is indicated for the treatment of pain and inflammation associated with osteoarthritis, rheumatoid arthritis, ankylosing spondylitis and inflammation due to surgery or physical trauma. |
| Reason: N/A |
| Ruling Date: March 26, 2025 |
N346412: The tariff classification of Midodrine Hydrochloride Tablets in dosage form, from India
| HTS: 3004.90.9221, free, “Medicaments… consisting of mixed or unmixed products for therapeutic or prophylactic uses, put up in measured doses … or in forms or packings for retail sale: Other: Other: Other: Cardiovascular medicaments: Other.” |
| Item: Midodrine Hydrochloride, imported in 2.5 mg, 5 mg and 10 mg tablets, is in a class of medications called alpha-adrenergic agonists. It is indicated for the treatment of orthostatic hypotension (OH). |
| Reason: N/A |
| Ruling Date: March 26, 2025 |
N346435: The country of origin of fuel modules
| Origin: Thailand |
| Item: The products at issue are a fuel pump and fuel modules. The modules primarily consist of a fuel pump, a float arm, a wiper seat. an ROV valve, a pressure sensor, a reservoir with a jet pump, and a resistance card seat. The fuel pump and the additional components work together to deliver fuel from the fuel tank to the engine management system. Components from China and Thailand are assembled together to form subassemblies. The subassemblies are then combined with one another to form the final product. The processes that produce the subassemblies and the final assembly processes occur in Thailand. |
| Reason: The components from China and Thailand are assembled together in Thailand to produce subassemblies, which are then combined with one another to form the complete module. The assembly processes that will occur 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. Based on the subassembly and final assembly processes described in the submission, the country of origin of the fuel modules is Thailand. |
| Ruling Date: March 26, 2025 |
N346500: The tariff classification of three decorative adhesive patches of man-made fibers from China
| HTS: 5810.92.1000, 9903.01.24, 9903.88.03, 4.2% + 20% + 25%, “Embroidery in the piece, in strips or in motifs: Other embroidery: Of man-made fibers: Badges, emblems and motifs.” |
| Item: The sample is the Lish Creative Adhesive Patches 3-Pack Assorted Design and features three different adhesive patches, which will be packaged and sold together. All three patches are composed of man-made fibers and feature embroidery. The first patch features an embroidered butterfly on a woven polyester twill fabric and measures 2½ inches x 2 inches. The second patch features an embroidered happy face featuring a smile face pattern on a woven polyester chenille fabric with a polyurethane (PU) glitter edge and measures 2 inches in diameter. The third patch features an embroidered mushroom on a woven polyester twill fabric and measures 2½ inches x 2 inches. Additionally, all three patches feature a polyethylene self-adhesive backing with a release paper, which can be used immediately after peeling off the release paper or, for a more secure attachment, it can be pressed at 135° for 6-8 seconds. The self-adhesive patches will come in assorted designs for craft applications on planning calendars and notebooks. They will not be advertised as iron-on patches and the consumer will be advised that these should be used similar to stickers. |
| Reason: N/A |
| Ruling Date: March 26, 2025 |
N346536: The tariff classification of live edge wood boards from Canada
| HTS: 4407.11.00, 9903.01.10, free + 25%, “Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm: Coniferous: Of pine (Pinus spp.)” |
| Item: The items under consideration are pine wood boards that are marketed to be used for furniture and shelving. The boards are imported in two styles: straight-sawn with at least one live bark edge, and rectangular-sawn (“square edge”). Each is sawn lengthwise along the grain of the wood. The boards are 2 inches thick and imported in various widths and lengths, depending on anticipated use. The boards are sanded but are not further worked in any way. After importation, customers will select hardware to convert the boards into furniture. However, at time of entry, the boards are not worked in any way that dedicates them for use as furniture, shelves, or any other item. All of the boards are wood sawn lengthwise along the grain. |
| Reason: The final two digits of the tariff classification will be based on the specific species of pine wood utilized. As the species has not been identified, the final two digits of the HTSUS code cannot be specified. |
| Ruling Date: March 26, 2025 |
N346557: The tariff classification of a transportation cask and disposable inserts from France
| HTS: 8609.00.0000, free, “Containers (including containers for the transport of fluids) specially designed and equipped for carriage by one or more modes of transport.” (Inserts) 7326.90.8688, 9903.81.90, 2.9% + 25%, “Other articles of iron or steel; Other; Other; Other; Other; Other.” |
| Item: An RT-200 cask system, Type B, which is a transportation cask primarily made of stainless steel. It entirely encloses a lead lining used as a shielding material. At each end of the cylindrical cask is an impact limiter secured by bolts. These impact limiters are also made of stainless steel and contain an enclosed polymer foam for energy absorption. The cylindrical cask holds a cylindrical basket body designed to secure up to three storage containers shored by a stainless steel disposable insert. The RT-200 is initially sold with disposable inserts. Additional disposable inserts may be purchased for import following the entry of the cask system. |
| Reason: N/A |
| Ruling Date: March 26, 2025 |
N346571: The tariff classification of a coolant nozzle from Taiwan
| HTS: 7616.99.5190, 9903.85.07, 2.5% + 25%, “Other articles of aluminum: Other.” |
| Item: The product under consideration is a coolant nozzle which is a machined nozzle designed as a component of a computer numerically controlled (CNC) machine tool coolant system. The nozzle is externally threaded on one side, and on the other side, the orifice from which the coolant is sprayed measures 0.166 inches in diameter. The body of the nozzle has a hex shape for tightly securing the nozzle to its fitting with the use of a wrench. The coolant nozzle is machined from aluminum alloy. The coolant nozzle will be principally used in the United States as a component of Haas CNC machining centers. |
| Reason: In the instant case, the coolant nozzle facilitates and directs the spray of coolant fluid as desired during operation. The inside diameter and length is designed to allow an optimal spray pattern which consequently affects the performance of a coolant subsystem. However, beyond the basic physical dimensions, the item does not feature specialized physical characteristics, adjustability, or mechanical components which provide unique and indispensable capabilities required for coolant subsystem functioning. |
| Ruling Date: March 26, 2025 |
N346743: The tariff classification of gesso-coated boards from Vietnam
| HTS: 4421.99.9880, 3.3%, “Other articles of wood: Other: Other: Other: Other: Other.” |
| Item: The products are finger jointed pine boards measuring approximately 16.7 mm in thickness, 4” to 12” in width, and 16’ to 17’ in length. All sizes 6” wide and greater are edge-glued. Each board is coated on 4 sides with gesso, a gypsum-based product that is applied to the board with an extruder. The gesso has visible thickness when viewing the board in cross section. The gesso applied to the boards is beyond the limits of priming, painting, or preservation. It is, instead, a coating, which, while acting as a primer, also fills imperfections and forms a refined, smooth surface to the wood. |
| Reason: N/A |
| Ruling Date: March 26, 2025 |