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.
N346664: The tariff classification and marking of adhesive tape with dispensers
| HTS: 3926.10.0000, 5.3%, “Office or school supplies” (of plastic) |
| Origin: Cambodia |
| Item: The product under consideration is a retail three-pack of adhesive tape rolls, each on a refillable plastic tape dispenser. The tape is of the kind commonly used in an office or school setting. The jumbo rolls of plastic are made in Malaysia, where they are also coated on one side with adhesive. The jumbo rolls are then sent to Cambodia for further processing. In Cambodia the rolls of adhesive plastic are cut to size and rewound onto smaller plastic cores; the cores are made in Cambodia. The tape dispensers are injection molded in Cambodia out of polystyrene plastic sourced from Vietnam. The packaging occurs in Cambodia where three rolls of tape, each on its own dispenser, are packaged together for retail in a paperboard box. |
| Reason: With respect to the dispensers and tape rolls comprising the set under consideration, and taking into account their roles with respect to the use of the set, the dispenser imparts the essential character to the set. The dispenser is sturdy and refillable and therefore can be refilled multiple times beyond its use with the provided tape rolls.The processing of the polystyrene resin into the finished tape dispenser through injection molding is considered to be a substantial transformation resulting in an article with a new name, character or use. Therefore, the country of origin of the dispensers will be Cambodia. |
| Ruling Date: March 31, 2025 |
N346810: The tariff classification of feminine hygiene products from Mexico
| HTS: 9619.00.2500, 9903.01.01, 6.3% + 25%, “Sanitary pads (towels) and tampons, diapers (napkins), diaper liners and similar articles, of any material: Of textile wadding.” |
| Item: The products under consideration are “Click Compact Tampons.” The tampons come in three levels of absorbency, Regular, Super, and Super Plus, and are packaged together in a “multipak” retail box. The applicators, which are made of plastic, consist of a barrel, a telescopic tube, and a plunger. The tampons have an inner core of textile wadding, which, per your submission, is rayon. This core has a nonwoven overwrap cover of semi-synthetic material. |
| Reason: N/A |
| Ruling Date: March 31, 2025 |
N346832: The tariff classification of an electric vehicle charging station from India
| HTS: 8537.10.9170, 2.7%, “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 collage not exceeding 1,000 V: Other: Other: Other.” |
| Item: The merchandise under consideration is identified as the Electric Vehicle Supply Equipment (EVSE), which is a wall mountable enclosure having an input cable and a 25-foot output cable with an SAE connector. The EVSE incorporates two printed circuit board assemblies, labelled the LED Board and the Main Board, where the latter distributes electricity by opening and closing relay(s) for the purpose of charging the connected vehicle’s batteries. However, the EVSE is limited to supplying unconditioned AC power to the vehicle and no power conversion occurs within the device as it takes in 240 VAC and distributes 240 VAC via the output cable. The EVSE is imported with a cradle/holster, mounting hardware, and a CleverKey ODB module. |
| Reason: N/A |
| Ruling Date: March 31, 2025 |
N346879: The tariff classification of the bezel assembly from China
| HTS: 8473.30.5100, 9903.01.24, 8473.30.5100, free + 20% + 25%, "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of heading 8470 to 8472: . . . Parts and accessories of the machines of heading 8471: Not incorporating a cathode-ray tube: . . . Other." |
| Item: The merchandise under consideration is the Bezel Assy, which is a bezel faceplate with locking key that is intended to be installed on the front of a 2U server. The Bezel Assy is constructed of plastic, metal, springs, and fasteners and is an accessory to data storage machines. |
| Reason: N/A |
| Ruling Date: March 31, 2025 |
N347064: The tariff classification of a costume from China and Vietnam
| 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 adult size costume identified as the Bloody Jester, which consist of a long sleeved pullover top, pull-on pants, separate collar, elongated stuffed finger gloves, headpiece and mask and features large, visible, loose overlock stitching on the neck. The sleeves have raw unfinished edges. The hem bottom has raw, jagged cut edges, giving a tattered appearance. The top is entirely constructed with long, loose straight stitching. |
| Reason: The flimsy man-made knitted textile top imparts the essential character of the set. |
| Ruling Date: March 31, 2025 |
N347070: The tariff classification of a costume from China and Vietnam
| 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 adult size costume identified as Giant Rat, which consists of a jumpsuit with three quarter length sleeves and a tail, mask, fingerless glovelettes and shoe covers and features a raw, unfinished neck and very deep back opening which is closed with a single patch of hook and loop fastener. The sleeves have large, visible, loose overlock stitching and exposed elastic stitched on with a single row of long, loose straight stitching. The leg openings have exposed elastic stitched on with large, loose overlock stitching. The jumpsuit is stitched together with a single row of long, loose, straight stitching. |
| Reason: The flimsy man-made faux fur textile jumpsuit provides the essential character of the set. |
| Ruling Date: March 31, 2025 |
N346572: The tariff classification of Diltiazem Hydrochloride (HCL) in Sodium Chloride Injection in dosage form, from Switzerland
| HTS: 3004.90.9218, 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: Containing diltiazem or its salts.” |
| Item: Diltiazem HCL in Sodium Chloride Injection, imported in dosage bags of 100 mg/100 mL, is a non-dihydropyridine calcium-channel blocker. It is indicated for the temporary control of rapid ventricular rate in atrial fibrillation or atrial flutter and rapid conversion of paroxysmal supraventricular tachycardias (PSVT) to sinus rhythm. |
| Reason: N/A |
| Ruling Date: March 28, 2025 |
N346614: The tariff classification of Divalproex Sodium Extended-Release Tablets in dosage form, from India
| HTS: 3004.90.9236, 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: Anticonvulsants, hypnotics and sedatives.” |
| Item: Divalproex Sodium, imported in 250 mg and 500 mg extended-release tablets, is an anticonvulsant. It is indicated for the acute treatment of manic or mixed episodes associated with bipolar disorder, with or without psychotic features. Divalproex Sodium is also indicated for the monotherapy and adjunctive therapy of complex partial seizures and simple and complex absence seizures and the prophylaxis of migraine headaches. |
| Reason: N/A |
| Ruling Date: March 28, 2025 |
N346339: The tariff classification of children’s waterproof boots from China
| HTS: 6401.92.9060, 9903.01.24, 9903.88.15, 37.5% + 20% + 7.5%, Waterproof footwear with outer soles and uppers of rubber or plastics, the uppers of which are neither fixed to the sole not assembled by stitching, riveting, nailing, screwing, plugging or similar processes: Other footwear: Covering the ankle but not covering the knee: Other: Other: Other |
| Item: Four styles of children’s closed toe/closed heel, waterproof rain boots. The boots cover the ankle, but not the knee. The uppers of all styles are made of vulcanized rubber, and the outsoles are rubber with applied leather flocking. The boots have a very thin leather flocking covering most of the outer surface that contacts the ground. However, the leather fibers are thinly applied on much of the outer soles but do not obscure the rubber/plastics material underneath. |
| Reason: N/A |
| Ruling Date: March 28, 2025 |
N346364: The tariff classification of items used in the production of oil and gas from China
| HTS: (1) 7326.90.8688, 9903.01.24, 9903.88.03, 2.9% + 20% + 25%, “other articles of iron or steel: other…other.” (2) 8481.90.9081, 9903.01.24, 9903.88.03, free + 20% + 25%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves: parts thereof: Parts: Other: Other: Other: Steel forgings.” (3) 8479.89.9550, 9903.01.24, 9903.88.03, 2.5% + 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: Oil and gas field wireline and downhole equipment.” (4) 7307.21.5000, 9903.01.24, 9903.88.03, 5.6% + 20% + 25%, “tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other, of stainless steel: flanges: other.” (4) 7307.99.5060, 9903.01.24, 9903.88.03, 4.3% + 20% + 25%, “tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other: other: other: of alloy steel (except stainless steel).” |
| Item: Items used to maintain pressure and containment within a wellbore. The four items will be constructed of alloy steel or stainless steel material. The first item is referred to as a casing head. The casing head is an adapter designed to be installed between a casing string and a blowout preventer stack or a wellhead. The second item is referred to as a cross. The cross, which consists of three or more connections, is used in a “Christmas Tree” (a specialized valve assembly). The third item is referred to as a casing hanger. The casing hanger supports the casing string when in a wellbore. The casing hanger positions a drilling string and is a sealing device. The fourth item is referred to as a flange. The flanges can be constructed of stainless steel or alloy steel and are used to connect pipes in order to control the flow of oil or gas coming out of a well. |
| Reason: N/A |
| Ruling Date: March 28, 2025 |