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.
N347140: The country of origin of a steering tie rod
| Origin: China |
| Item: The item under consideration is a Steering Tie Rod, which is used in passenger vehicles. It provides directional control of a car. The steering tie rod weighs approximately 2 pounds. It consists of a ball pin, steering rod, cotter pin, castle nut, dust cover, dust boot, plastic seat, and top cover. The ball pin and steering rod forgings are made in China and shipped to Thailand for further processing. In Thailand, the forgings undergo precision drilling, machining, thread tapping, and tapping and milling with advanced CNC machines. The parts are then assembled with the rest of the components of Thai origin, by riveting and fitting components together. |
| Reason: The Chinese forgings do not undergo a significant change in Thailand. The machining, drilling, tapping, and milling, as well as the addition of Thai sourced rubber and plastic components, do not transform the character of the forgings into a new article with a new name, character, or use. As a result, no substantial transformation occurs in Thailand, and the country of origin of the Steering Tie Rod is China. |
| Ruling Date: April 8, 2025 |
N347292: The country of origin of diodes
| Origin: U.S. |
| Item: The items concerned are “Surface-Mount Mixer/Detector Schottky Diodes” (1) and “Surface-Mount Silicon Varactor Diode (2).” Each diode undergoes a front-end and back-end manufacturing processing. The front-end manufacturing processes take place in the United States and consist of altering a raw wafer or substrate with the following processes: Oxide/Nitride/Metal deposition Photolithography Etching Metal deposition Wafer thinning Manual and on-wafer (die) testing Automated visual inspection. The back-end manufacturing processes take place in China and consist of the following steps:Multiple quality check/inspection/testing stages Verifying the device information in the assembly instruction matches the material (wafer) being assembled Wafer mounting Sawing into individual die Die packaging Multiple baking/curing stages Wire bonding the diode contacts to the lead frame of the end device package Molding/encapsulating Removing excess material Backside marking Plating Forming The front-end manufacturing processing, particularly wafer fabrication steps like oxide/nitride/metal deposition, etching, and photolithography are key steps to make each diode functional. Once the front-end manufacturing process is complete, the diode has all the necessary elements to function as intended. The basic functionality of the diodes is not dependent upon the back-end manufacturing process. |
| Reason: The front-end processing that takes place in the United States is both meaningful and complex, resulting in the creation of wafers which incorporate numerous finished diode chips/die. The character of the finished/packaged diodes is imparted by the diode chip/die (which was formed on the wafer). The diode chip/die would be considered the dominant component. The diode chips/die do not undergo a substantial transformation as a result of the back-end processing that takes place in China. They retain their identity and predetermined end use which was established as a result of the front-end processing. Therefore, since a substantial transformation does not occur as a result of the back-end processing that takes place in China, the country of origin of the “Surface-Mount Mixer/Detector Schottky Diodes” and the “Surface-Mount Silicon Varactor Diode” will be the United States. |
| Ruling Date: April 8, 2025 |
N346621: The tariff classification of Leucovorin Calcium Injection in dosage form, from Switzerland
| HTS: 3004.50.4000, 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, containing vitamins or other products of heading 2936: Containing vitamins synthesized wholly or in part from aromatic or modified aromatic industrial organic compounds: Other.” |
| Item: Leucovorin Calcium Injection, imported in 100 mg/10 mL, 200 mg/20 mL, and 350 mg/17.5 mL vials, is a derivative of folic acid indicated for rescue after high-dose methotrexate therapy in osteosarcoma. It is also indicated for diminishing the toxicity and counteracting the effects of impaired methotrexate elimination and of inadvertent overdosages of folic acid antagonists. Leucovorin Calcium is also indicated in the treatment of megaloblastic anemias due to folic acid deficiency when oral therapy is not feasible. |
| Reason: N/A |
| Ruling Date: April 7, 2025 |
N346694: The tariff classification of a glass Christmas ornament from China
| HTS: 9505.10.1000, 9903.88.15, 9903.01.24, free + 7.5% + 20%, “Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Articles for Christmas festivities and parts and accessories thereof: Christmas ornaments: Of glass.” |
| Item: An item identified as a Glass Nutcracker, which consists of a decorative solid glass figurine depicting a traditional soldier nutcracker standing “at attention.” The clear glass item measures approximately 3.54"(L) x 3.54" (W)x 15.75"(H). The item is permanently attached to a glass base said to measure approximately 3.54"(L) x 3.54" (W)x .36”(H). The item is marketed and sold exclusively as a Christmas decoration for the home. |
| Reason: N/A |
| Ruling Date: April 7, 2025 |
N346900: The country of origin of a double flanged wheel hub unit with ball bearings
| Origin: Thailand |
| Item: The merchandise under consideration is a Double Flanged Wheel Hub Unit Incorporating Ball Bearings, which is used in passenger vehicles. The assembly features an outer flange and an inner flange, which work together to support the wheel and axle connection. The outer flange is typically bolted to the wheel, providing a secure mounting point, while the inner flange connects to the axle, via a splined interface for torque transmission. Between the flanges, the rotating body, which includes the ball bearings, allows for low-friction rotation of the wheel. The assembly also integrates an anti-lock braking system (ABS) sensor, which monitors wheel speed for anti-lock braking functionality. The outer and inner flanges are produced in Thailand from raw steel bars. The bars undergo hot forging, normalizing, shot blasting, turning 1, heat treatment, turning 2 and 3, and drilling. The outer flange then undergoes additional outer diameter grinding, raceway grinding, and superfine grinding. The inner flange undergoes additional splining, raceway grinding, and superfine griding. The outer and inner flanges are then assembled together in Thailand with the Chinese sourced inner ring, steel balls, cage, seal ring, ABS sensor, and bolts. Finally, the unit is greased with the Thai sourced grease and anti-rust oil and packaged for shipment to the United States. |
| Reason: Since the flanges in the current ruling are made in Thailand and the spline and raceway components are also ground in Thailand, the country of origin of the entire wheel hub unit incorporating ball bearings will be Thailand. |
| Ruling Date: April 7, 2025 |
N346947: The country of origin of a double flanged wheel hub unit with roller bearings
| Origin: Thailand |
| Item: The article under consideration is the Double Flanged Wheel Hub Unit with Tapered Roller Bearings, which is used in passenger vehicles. The outer and inner flanges are made in Thailand, while the rest of the components (i.e., cage, tapered rollers, seal ring, dust cover, ring gear, bolt, ABS sensor, and inner ring) are made in China and imported into Thailand for final assembly. In Thailand, the outer flange is made from a metal rod that undergoes cutting, hot forging, normalizing, shot blasting, turning 1, heat treatment, turning 2 and 3, drilling, outer diameter grinding, raceway grinding, and superfine grinding. The inner flange is made from a metal rod and undergoes cutting, hot forging, normalizing, shot blasting, turning 1, heat treatment, drilling, and turning 2 and 3. The wheel bearing unit assembly process includes installing rolling elements, pressing the ring gear, fitting bolts, installing the seal ring, performing clearance detection, applying grease, assembling components, conducting another clearance check, cold forming, crack detection, vibration testing, installing seal ring, installing and measuring the ABS sensor, laser marking, applying anti-rust oil, and packaging/packing according to customer specifications before being shipped to the United States. |
| Reason: The flanges are of Thai origin, while the race is of Chinese origin. Due to the fact that the final assembly occurs in Thailand, and the value of the Thai components amounts to approximately 69.2% of the total cost, the country of origin for the double flanged wheel hub unit incorporating tapered roller bearings will be Thailand. |
| Ruling Date: April 7, 2025 |
N347034: The country of origin of fiber optic cable assemblies
| Origin: U.S. |
| Item: The merchandise under consideration is described as five models of a fiber optic patch cord assembly. The subject assemblies are further described as fiber optic cables that consist of a fiber optic core, which consists of 8, 16, or 144 optical fibers depending on the model number. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The subject cables are used within various telecommunications industries to transfer optical data signals. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and prepared for the addition of the connectors. The connectors are then assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S. |
| Reason: Regarding the origin of the subject fiber optic cable assemblies, the fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce. The origin of the fiber optic patch cord assembly will be the United States. |
| Ruling Date: April 7, 2025 |
N347449: The tariff classification of Water Globes 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 glass water globe, which consists of an assortment of two styles of water globes. Although both designs feature glass globes, the articles are overwhelmingly constructed of non-glass material (polyresin and stone powder). Both designs will be marketed and sold separately as decorations for Christmas. The first design, Nutcracker and Snowflake, features a single nutcracker soldier figurine with a large snowflake as a background, inside a glass globe filled with water, faux snow and small sequins. The base of the globe depicts a drum. When the globe is shaken, the globe’s interior is filled with simulated falling snow. The item measures approximately 3.93” in diameter and 5.1” in height. The second design, 3PC Gold Nutcracker, features a group of three nutcracker soldier figurines in gold color, inside a glass globe filled with water, faux snow and small sequins. The base of the globe has a ribbed design. When the globe is shaken, the globe’s interior is filled with simulated falling snow. The item measures approximately 3.93” in diameter and 5.4” in height. |
| Reason: N/A |
| Ruling Date: April 7, 2025 |
N347264: The tariff classification of wall hooks from China
| HTS: 3925.90.0000, 9903.01.24, 9903.88.03, 5.3% + 20% + 25%, “builders’ ware of plastics, not elsewhere specified or included: other.” |
| Item: The product under consideration is referred to as Clear Mini Hooks. The blister package contains 12 clear plastic hooks and 12 adhesive strips with release backing. The adhesive strips are first attached to the hook and then attached to a wall to hold various items. |
| Reason: N/A |
| Ruling Date: April 4, 2025 |
N346575: The tariff classification and country of origin marking of two unassembled gate latches
| HTS: 8302.49.6085, 5.7%, “Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like …: Other mountings, fittings and similar articles, and parts thereof: Other: Other: Of iron or steel, of aluminum or of zinc: Other: Other.” |
| Origin: China |
| Item: The products under consideration are a Toggle Latch (T-Latch) and a Q-bolt Latch (Q-Latch). Both of these products are latches for a gate. For each latch the steel component functions to hold the gate closed and is the most expensive component. The stainless-steel T-latch striker pin and Q-bolt drop rod are made in China; the steel screws are made in Taiwan; and the plastic housings, the packaging bags, stickers, and instructions are made in Australia. The T-latch striker pins, Q-bolt drop rods, and screws are shipped to Australia where workers package them together with the plastic housings for exportation to the United States. The stainless-steel T-latch striker pin and Q-bolt drop rod are made in China; the steel screws are made in Taiwan; and the plastic housings, the packaging bags, stickers, and instructions are made in Australia. The T-latch striker pins, Q-bolt drop rods, and screws are shipped to Australia where workers package them together with the plastic housings for exportation to the United States. |
| Reason: With respect to these gate latches, it must determined whether the plastic housing or the T-latch striker pin and Q-bolt drop rod imparts the essential character to the subject gate latches. It is the role of the constituent materials or components in relation to the use of the good that imparts the essential character. In this case, the steel components function as the fastening mechanism to hold the gate closed. The steel components predominate by value. Therefore, the steel T-latch striker pin and Q-bolt drop rod impart the essential character to the composite articles. In accordance with GRI 3(b) the gate latches will be classified by their base metal component.As indicated above, the steel T-latch striker pin and Q-bolt drop rod that are made in China provide the essential character of both gate latches. The simple combining of components is not sufficient to effect a substantial transformation of the Chinese-origin T-latch striker pin and Q-bolt drop rod. As such, the country of origin for the gate latches for marking purposes is China. |
| Ruling Date: April 4, 2025 |