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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N347261: The tariff classification of an insulated cooler bag from China
| HTS: 4202.92.0807, 9903.01.24, 9903.01.63, 9903.88.03, 7% + 20% + 125% + 25%, “insulated food and beverage bags, with outer surface of sheeting of plastic or of textile materials, with outer surface of textile materials, other, of man-made textiles.” |
| Item: An insulated cooler bag with an outer surface of a man-made textile material. It is designed to provide storage, protection, organization, and portability to food and beverages during travel. The bag is also designed to maintain the temperature of food and beverages. There is a layer of foam plastics between the exterior of the bag and the lining. The article features a zippered closure at the top, one handle, and one adjustable shoulder strap. The front features one zippered pocket with a permanently attached metal bottle opener. It measures 9 inches (L) by 5.5 inches (W) by 11.5 inches (H). |
| Reason: N/A |
| Ruling Date: April 16, 2025 |
N347299: The tariff classification of an iron pedestal bowl from India
| HTS: 7323.99.9080, 9903.01.25, 9903.81.90, 3.4% + 10% + 25%, “Table, kitchen or other household articles and parts thereof, of iron or steel; Other: Other: Not coated or plated with precious metal: Other: Other. Other.” |
| Item: The merchandise under consideration is an iron pedestal bowl. A pedestal supports the circular iron blue bowl, which is available in small and large sizes. The small bowl measures approximately 7.5 inches wide by 7.5 inches deep by 2.95 inches high. The large bowl measures approximately 9.25 inches wide by 9.25 inches deep by 3.58 inches high. The items will be sold separately and that the bowl is intended for home use and is unsafe for food contact. |
| Reason: Despite references to the circular blue pedestal bowl as a tray, a tray is an open receptacle wide enough to support and carry dishes, plates, bowls, and drinking vessels, which in turn, hold and serve food and beverages. Therefore, the item is not a tray, but a bowl. |
| Ruling Date: April 16, 2025 |
N347384: The tariff classification of women’s knit garments from China
| HTS: (Style 1) 6114.30.3070, 9903.01.24, 9903.01.63, 9903.88.15, 14.9% + 20% + 125% + 7.5%, “Other garments, knitted or crocheted: Of man-made fibers: Other: Other: Women’s or Girls’.” (Style 2) 6211.43.1078, 9903.01.24, 9903.01.63, 9903.88.15, 16% + 20% + 125% + 7.5%, “Track suits, ski-suits and swimwear: other garments: Other garments, women’s or girls’: Of man-made fibers: Other: Jackets and jacket-type garments excluded from heading 6202.” |
| Item: Style 1 is a woman’s garment constructed from 100% polyester open work knit fabric. The garment extends from the shoulders to below the waist. The garment features a full front opening, drop sleeves, and rib-knit edging. Style 2 is a woman’s garment constructed from 100% polyester woven fabric. The garment features a V-neckline, short sleeves, an unsecured full front opening, and a hemmed bottom. |
| Reason: N/A |
| Ruling Date: April 16, 2025 |
N347448: The tariff classification of golf umbrellas from China
| HTS: 6601.99.0000, 9903.01.24, 9903.01.63, 8.2% + 20% + 125%, “Umbrellas and sun umbrellas (including walking-stick umbrellas, garden umbrellas and similar umbrellas): Other: Other.” |
| Item: A golf umbrella. The shaft and frame are constructed from fiberglass, while the canopy, which measures approximately 53 inches across when open, is made from 100% polyester pongee. It features a vented top section. The umbrella is collapsible (opens and closes), but the shaft is not telescoping; rather, the shaft is a fixed length. |
| Reason: N/A |
| Ruling Date: April 16, 2025 |
N347549: The tariff classification of scented stickers from China
| HTS: 4911.91.2040, 9903.01.24, 9903.01.63, free + 20% + 125%, “Other printed matter, including printed pictures and photographs: Other: Pictures, designs and photographs: Printed not over 20 years at time of importation: Other: Lithographs on paper or paperboard: Not over 0.51 mm in thickness: Other.” |
| Item: The “Scentos sticker sheets- Fruits,” is a retail package of scented, self-adhesive, paper stickers. The lithographically printed stickers are colorfully illustrated with fruits and animated versions of fruit. They are scented to correspond to the fruit depicted. |
| Reason: N/A |
| Ruling Date: April 16, 2025 |
N347847: The tariff classification of Christmas decorations from China
| HTS: 9505.10.2500, 9903.01.24, 9903.01.63, free + 20% + 125%, “Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Christmas ornaments: Other: Other.” |
| Item: Three conical, battery-powered, illuminated, ceramic Christmas tree decorations. Each tabletop decoration is said to measure approximately 8 inches wide x 11 inches tall. All three items are marketed and sold exclusively as Christmas decorations for the home. The first item features a Nightmare Before Christmas-themed, illuminated, Christmas tree decorated with a gold star tree-topper and is futher decorated with images of ball-shaped Christmas ornaments with the depiction of Disney’s Jack Skellington’s face on each. A three-dimensional figure of Zero, the ghost dog, is curled up at the base of the tree in between two wrapped presents. When powered on, the light inside glows through star and moon shaped cut outs in the ceramic. The second item features Disney’s Mickey Mouse. The illuminated, Mickey Mouse-themed ceramic Christmas tree is designed to look as if made of holly leaves and decorated with holly berries as well as the iconic Mickey Mouse head topper. The tree is further decorated with smaller Mickey Mouse heads, and red plastic bulbs. The tree sits on a circular base. When powered on, the light inside glows through the red bulbs. The third item features the three-dimensional Disney characters Pooh, Tigger, Eeyore, and Piglet from Disney’s Winnie the Pooh, wearing Santa hats, all sitting together at the base of an illuminated, ceramic Christmas tree dusted with glitter “snow” and decorated with a big honeybee as a tree topper and colored plastic bulbs. When powered on, the light inside glows through the colored plastic bulbs. |
| Reason: N/A |
| Ruling Date: April 16, 2025 |
N347890: The country of origin of radio frequency (RF) front-end-modules. Correction to Ruling Number N346922
| Origin: U.S. |
| Item: The items concerned are referred to as radio frequency (RF) front-end-modules (FEM). These devices are silicon on insulator (SOI) RF FEM integrated circuits (ICs). They are used in cellular and Wi-Fi applications. The RF FEM integrated circuit manufacturing process is divided into three basic phases: (1) the front-end manufacturing process, which occurs in the United States, (2) the back-end package assembly process, which occurs in China, and (3) the final testing and finishing, which occurs in the United States. The front-end manufacturing process determines all the inherent performance parameters of the RF FEM products. At the conclusion of the front-end manufacturing process, the RF FEM dice are complete, having their full operational capability. The RF FEM dice then undergo package assembly, followed by a final testing and finishing process. The front-end manufacturing process which takes place within the United States comprises ten primary steps, some of which are repeated multiple times. Within the United States, the process begins with a raw SOI substrate wafer originating from France, Japan, or the United States. The substrate then undergoes multiple photolithographic and chemical processing steps to transform the wafer into a set of RF FEM integrated circuits (i.e., chips or die). |
| 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 RF FEM integrated circuit die. All non-originating materials, used in the manufacture of the wafers containing the RF FEM integrated circuit die, are substantially transformed as a result of the front-end processing that takes place within the United States. The character of the finished/packaged RF FEM integrated circuit module is imparted by the IC chips/die which would be considered the dominant component. The RF FEM integrated circuit die does not undergo a substantial transformation as a result of the back-end processing that takes place in China. The RF FEM integrated circuit die 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 within China, the country of origin of the finished RF FEM integrated circuit module will be the United States; therefore, trade remedies under Section 301 will not apply. |
| Ruling Date: April 16, 2025 |
N346712: The tariff classification of an artificial stone candy bowl from China
| HTS: 6810.99.0080, 9903.01.24, 9903.01.63, free + 20% + 125%, “Articles of cement, of concrete or of artificial stone, whether or not reinforced: Other articles: Other: Other.” |
| Item: The item is a candy bowl which measures approximately 16 inches tall by 7.5 inches wide at its widest points. It is shaped to resemble a cartoon-style mummy holding a dark gray bag which bears the legend “Happy Halloween” in black lettering. The mummy’s head forms a bowl which is approximately 5.5 inches deep. On the inside of the bowl are a built-in motion sensor and speaker. When someone reaches into the bowl, the motion sensor is tripped and the speaker emits a laughing sound. This feature is powered by 2 AA batteries housed in the bottom of the mummy’s feet. From the information you provided, this candy bowl is made of artificial stone comprised of 50% by weight crushed natural calcite uniformly agglomerated with 50% by weight polyresin. |
| Reason: N/A |
| Ruling Date: April 15, 2025 |
N346745: The tariff classification of three steel support rail items from Canada
| HTS: 8302.41.6080, 3.9%, “Base metal mountings, fittings and similar articles… Other mountings, fittings, and similar articles, and parts thereof: Suitable for buildings: Other: Of iron or steel, of aluminum or of zinc … Other.” |
| Item:The first item under consideration is the Advantage Rail. It is a steel floor mounted support rail that can pivot and lock in eight positions. It consists of a vertical pole that is bolted onto the floor and a height adjustable horizontal rail. It functions to provide sitting and standing support for people with reduced mobility. The Advantage Rail complies with the American Disabilities Act (ADA) requirements for rail diameter and structural strength. The second item under consideration is the P.T. Rail Floor Mast. It is a rectangular column that is made of either steel or stainless steel. The P.T. Rail Floor Mast complies with the ADA requirements for structural strength. The third item under consideration is the P.T. Rail Hinged. It is a toilet support grab rail that can fold down when needed for support and fold up when not in use. It is permanently installed on the wall behind the toilet or on the P.T. Rail Floor Mast next to the toilet so that the rail can extend lengthwise to the left and/or right side(s) of the toilet. The P.T. Rail is made of either steel or stainless steel. The P.T. Rail Hinged is ADA compliant for structural strength and rail diameter. |
| Reason: The Advantage Rail and the P.T. Rail Hinged are eligible for duty-free treatment in subheading 9817.00.96, which provides for articles which are specially designed or adapted for the use or benefit of the permanently or chronically physically or mentally handicapped. However, while the P.T. Rail Floor Mast is designed to be used with the P.T. Rail, it does not have distinguishing features that indicate it is used by handicapped individuals. It is merely a metal column that can be bolted in place. Accordingly, the P.T. Rail Floor Mast does not satisfy the description set forth in Chapter 98, Subchapter XVII, U.S. Note 4(a). Therefore, this article is not eligible for duty-free treatment under secondary classification under subheading 9817.00.96. |
| Ruling Date: April 15, 2025 |
N346814: The tariff classification of a valve arrangement from the United Kingdom
| HTS: 8481.80.9005, 9903.01.25, 2% + 10%, “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: Other appliances: Other: Solenoid valves.” |
| Item: The ExiInta, which is a block and bleed valve arrangement, is used in process, utility and service lines of sanitary and hygienic separation installations. The ExiInta valve arrangement consists of a steel housing that encases basic electronic components, solenoid valves that control the flow of waste, and pressure sensors that send information that contribute to the operation of the solenoid valves. |
| Reason: N/A |
| Ruling Date: April 15, 2025 |