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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N346936: The tariff classification of Panna Cotta from Italy
| HTS: (If within limits) 1901.90.6100, 16%, “Food preparations of goods of headings 0401 to 0404, not containing cocoa…: Other: Other: Dairy products described in additional U.S. note 1 to chapter 4: Dairy preparations containing over 10 percent by weight of milk solids: Described in additional U.S. note 10 to chapter 4 and entered pursuant to its provisions.” (If over limits) 1901.90.6200, $1.035/kg + 13.6%, “Food preparations of goods of headings 0401 to 0404, not containing cocoa…: Other: Other: Other.” |
| Item: The subject merchandise is Azienda Agricola Fusero Panna Cotta Naturale ready-to-eat dessert. The pudding-like product is composed of whole milk (62%), cream (25%), sugar, dextrose, corn starch, and edible gelatine as a thickener. The product contains 13% nonfat milk solids. The Panna Cotta Naturale will be imported in 135-gram paper cups packed ten to a cardboard 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: April 1, 2025 |
N346959: The tariff classification of a battery pack from China
| HTS: 8507.60.0020, 9903.88.15, 9903.01.24, 3.4% + 7.5% + 20%, “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Lithium-ion batteries: Other.” |
| Item: The merchandise under consideration is a rechargeable lithium-ion battery pack, which is a portable device for storing and supplying electricity. It consists of twelve cylindrical battery cells enclosed in a rectangular housing with a built-in USB-C cable, DC connector port, RC connector port, power button, and LED indicator lights. The battery pack has an output voltage of 5 VDC (USB-C), an output voltage of 37 VDC (DC port), a nominal capacity of 2600 mAh, and a nominal energy of 96.2 Wh. The battery pack is used to power electric luggage scooters but can also be used to power electronic devices, such as tablets and smartphones. |
| Reason: N/A |
| Ruling Date: April 1, 2025 |
N346963: The tariff classification and country of origin of under-the-sink water filtration systems
| HTS: 8421.21.0000, free, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” |
| Origin: South Korea |
| Item: The items under consideration are Single-Stage Carbon Block Under Sink Water Filtration Systems, which provide clean water directly from a faucet. The products generally follow the same structure and packaging steps, with the only differences being in specifications and dimensions. The devices connect to the cold-water line leading to the sink. The filters are designed to reduce chlorine, contaminants, and odor for better tasting water. The filters are to be discarded and replaced by a consumer approximately every twelve months. |
| Reason: The assembly process performed in China is not considered complex and does not constitute a substantial transformation. While there are many different individual components, each component only performs a small function for the overall system. Additionally, the construction of the filter itself predominantly involves gluing, welding, and pressing various components into place. The combining of all of the parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration Systems, it is the origin of the carbon block, which provides the essential function of the entire system. It is the carbon block from South Korea which requires considerable technical expertise and customized equipment to produce. It is also the most expensive portion of the system and is the item performing the filtering of the water. Accordingly, the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration Systems is South Korea |
| Ruling Date: April 1, 2025 |
N346964: The tariff classification and country of origin of under-the-sink water filtration systems
| HTS: 8421.21.0000, free, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” |
| Origin: South Korea |
| Item: The items under consideration are Single-Stage Carbon Block Under Sink Water Filtration Systems, which provide clean water directly from a faucet. The products generally follow the same structure and packaging steps, with the only differences being in specifications and dimensions. The devices connect to the cold-water line leading to the sink. The filters are designed to reduce chlorine, contaminants, and odor for better tasting water. The filters are to be discarded and replaced by a consumer approximately every twelve months. |
| Reason: The assembly process performed in China is not considered complex and does not constitute a substantial transformation. While there are many different individual components, each component only performs a small function for the overall system. Additionally, the construction of the filter itself predominantly involves gluing, welding, and pressing various components into place. The combining of all of the parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration Systems, it is the origin of the carbon block, which provides the essential function of the entire system. It is the carbon block from South Korea which requires considerable technical expertise and customized equipment to produce. It is also the most expensive portion of the system and is the item performing the filtering of the water. Accordingly, the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration Systems is South Korea. |
| Ruling Date: April 1, 2025 |
N346965: The tariff classification and country of origin of under-the-sink water filtration systems.
| HTS: 8421.21.0000, free, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” |
| Origin: South Korea |
| Item: The items under consideration are Single-Stage Carbon Block Under Sink Water Filtration Systems, which provides clean water directly from a faucet. The products generally follow the same structure and packaging steps, with the only difference being the WD-15UC is black in color and the WD-15UCW is white in color. The devices connect to the cold-water line leading to the sink. The filters are designed to reduce chlorine, contaminants, and odor for better tasting water. The filters are to be discarded and replaced by a consumer approximately every twelve months. |
| Reason: The assembly process performed in China is not considered complex and does not constitute a substantial transformation. While there are many different individual components, each component only performs a small function for the overall system. Additionally, the construction of the filter itself predominantly involves gluing, welding, and pressing various components into place. The combining of all of the parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration Systems, it is the origin of the carbon block, which provides the essential function of the entire system. It is the carbon block from South Korea which requires considerable technical expertise and customized equipment to produce. It is also the most expensive portion of the system and is the item performing the filtering of the water. Accordingly, the country of origin of the Single-Stage Carbon Block Under Sink Water Filtration Systems is South Korea. |
| Ruling Date: April 1, 2025 |
N347004: The tariff classification, marking, and status under the United States-Mexico-Canada Agreement (USMCA) of horse semen from Canada
| HTS: 0511.99.4040, 1.1%, “Animal products not elsewhere specified or included; dead animals of chapter 1 or 3, unfit for human consumption: Other: Other: Other: Other animal semen.” |
| Item: The subject merchandise is Standardbred horse semen. Stallions will produce the semen that is collected through veterinary procedures and then inserted into syringes of 50 cubic centimeters. The semen will be used to inseminate and impregnate Standardbred mares through artificial means. The merchandise will be imported to the United States in ten syringes of 50 cubic centimeters each, which are then packed in Styrofoam boxes weighing 4 lbs. |
| Reason: The horse semen is “wholly obtained or produced” from horses located and originating in Canada. Therefore, paragraph (a)(1) can be used to determine the country of origin of the semen, which in this case is Canada. Articles on the J-List are exempt from individual marking, but the outermost container that ordinarily reaches the ultimate purchaser of a J-List article must be marked with the country of origin of the article, in this case Canada. |
| Ruling Date: April 1, 2025 |
N347027: The tariff classification of a knot wrap from India
| HTS: 6307.90.9891, 7%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Item: The sample described as a “Knot Wrap” is textile gift wrap intended to be a reusable alternative to paper gift wrap. The item is composed of 100% cotton woven fabric and the edges are folded over and hemmed on four sides. The square shaped wrap is available in various screen prints and two sizes: 20 inches by 20 inches and 27-1/2 inches by 27-1/2 inches. The item can be used to pack one’s lunch or as a scarf. |
| Reason: N/A |
| Ruling Date: April 1, 2025 |
N347045: The tariff classification of paper packaging components and a registration card from Cambodia or China
| HTS: (printed paper label) 4821.10.4000, 9903.01.24, 9903.88.03, free + 20% + 25%, “Paper and paperboard labels of all kinds, whether or not printed: Printed: Other.” (structural cardboard inserts) 4823.90.8680, 9903.01.24, 9903.88.03, free + 20% + 25%, “Other paper, paperboard, cellulose wadding and webs of cellulose fibers, cut to size or shape; other articles of paper pulp, paper, paperboard, cellulose wadding or webs of cellulose fibers: Other: Other: Other: Other: Other: Other.” (registration cards) 4907.00.0000, 9903.01.24, free + 20%, “Unused postage, revenue or similar stamps of current or new issue in the country in which they have, or will have, a recognized face value; stamp-impressed paper; banknotes; check forms; stock, share or bond certificates and similar documents of title.” |
| Item: Item 1 is a die-cut label printed with product information about a plastic baby tub. The label is made from e-flute cardboard (a variety of thin corrugated cardboard), is printed (not lithographically) with five-color print, and is laminated with a matte plastic film. The label is printed on both sides with pictures, usage and safety information, and more. After importation, the label will be applied to the tub for retail sale. Items 2 and 4 are structural cardboard inserts. One is a strip of corrugated cardboard that is folded into a triangle and taped into shape. The second is a strip of corrugated cardboard that is folded into a rectangle and taped into shape. The inserts appear to function as spacers between the product and label or other items. Item 3 is a printed registration card. The card is inkjet-printed and is to be filled out by the consumer and returned to the manufacturer after retail purchase. The card is scored for folding in half and is printed on one side with spaces for the consumer to complete with their personal and product information. The other side is pre-addressed and postage-paid for convenient return. Item 1 is a paperboard label. |
| Reason: N/A |
| Ruling Date: April 1, 2025 |
N346446: The tariff classification of seamless copper tubes from Vietnam
| HTS: 7411.10.1090, 1.5%, “copper tubes and pipes, of refined copper, seamless, other.” |
| Item: The products to be imported are described as seamless alloy tubes meeting ASTM B75, 251, 743, the standard specification for Copper Alloy (UNS C14435). The subject tubes will be imported in both straight lengths and in coils with outside diameters ranging from 4.78 mm – 22.23 mm and wall thicknesses ranging from 0.34 mm – 1.20 mm. The tubes consist of 99.5% copper and 0.3% - 0.5% tin and are designed for high pressure and refrigerant heat transfer applications. |
| Reason: N/A |
| Ruling Date: March 31, 2025 |
N346484: The tariff classification of Derma Roller from China
| HTS: 8205.51.3060, 9903.88.03, 9903.01.24, 3.7% + 25% + 20%, “handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: household tools, and parts thereof: of iron or steel: other (including parts): other (including parts).” |
| Item: The merchandise under consideration is identified as a Derma Roller. It is a hand-operated tool with an aluminum handle and small blunt stainless-steel needles mounted on a roller. The tool measures 151.5 mm in overall length and the head of the tool measures 29.74 mm in width. The user rolls the tool over areas of the scalp in order to create tiny holes in the skin. The tool is meant to be used in conjunction with shampoo and a hair serum to help stimulate and gently exfoliate the scalp. The item is a personal care tool and not meant to be used by medical professionals. |
| Reason: N/A |
| Ruling Date: March 31, 2025 |