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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N347685: The tariff classification of steel storage units from Turkey
| HTS: 9406.90.0130, 9903.01.25, 2.9% + 10%, “Prefabricated buildings: Other: Of metal: Other.” |
| Item: The product under consideration is flat-pack, container-style storage units. The units are made of steel and have four walls, a roof, and a floor. Each unit has at least one door for entry by a human to store goods inside. The units are shipped flat and assemble easily within 30 minutes. They are imported in multiple styles and colors. The storage units are built to withstand the elements and are empty inside with no shelves or fixtures. The units are movable by forklift, but are designed to remain generally in one location, not for use in the conveyance of goods. |
| Reason: N/A |
| Ruling Date: April 18, 2025 |
N347688: The tariff classification of oak wood planks from Chile
| HTS: 4407.91.0063, 9903.01.25, free + 10%, “Wood sawn or chipped lengthwise, sliced or peeled, whether or not planed, sanded or end-jointed, of a thickness exceeding 6 mm: Other: Of oak (Quercus spp.): Other.” |
| Item: The product under consideration is oak wood planks. The wood is sawn lengthwise along the grain. The two samples provided measure 23cm long by 5cm wide by 7.38mm thick and 20cm long by 13cm wide by 12cm thick. The oak wood has been dried and/or heated in a convection oven. The wood planks are intended to be put into wine barrels to flavor wine. The oak wood is French oak (Quercus petrae) or American oak (Quercus alba). |
| Reason: N/A |
| Ruling Date: April 18, 2025 |
N346924: The tariff classification of iron wreath hangers from China
| HTS: 8302.50.0000, 9903.01.24, 9903.01.63, 9903.88.03, free + 20% + 125% + 25%, “Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar fixtures; …: Hat-racks, hat pegs, brackets and similar fixtures, and parts thereof.” |
| Item: The merchandise under consideration is a “Wreath Hanger with decorative icon.” These iron metal hangers have an over-the-door hook on top and a rounded hook on the bottom that can be used to hang wreaths or other items. There are 5 different groups of hangers. The first 4 groups of hangers are decorated with an iron metal icon near the top and measure approximately 12.5-inches long, 1-inch wide, and fit doors up to 2-inches thick. Item number 1 features four different designs on white hangers depicting an Easter theme: 2 carrots with the words “Hop On In!”, a decorated egg with the words “Happy Easter,” a bunny head and front paws, and a bunny tail and back paws. Item number 2 features 4 different designs depicting an autumn theme: 3 mushrooms with leaves on a red hanger, 3 sunflowers with leaves on a yellow hanger, an autumn wreath encircling the words “Autumn is Calling” on a maroon hanger, and 4 gourds and leaves on a green hanger. Item number 3 features 2 different designs depicting a Christmas theme: a red reindeer on a white hanger, and a red plaque with the words “Merry Christmas” on a green hanger. Item number 4 features 4 different designs on black hangers depicting a Halloween theme: a skeleton hand, a smiling ghost, 2 large green eyes, and 3 bats. The 5th group of hangers measures approximately 13-inches long, 1-inch wide, and fits doors up to 2-inches thick. Item number 5 features 2 designs: a gold hanger with 3 gold jingle bells near the top, and a silver hanger with 3 silver jingle bells near the top. |
| Reason: N/A |
| Ruling Date: April 17, 2025 |
N346991: The tariff classification of iron wreath hangers from China
| HTS: 8302.50.0000, 9903.01.24, 9903.01.63, 9903.88.03, free + 20% + 125% + 25%, “Base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like; base metal hat racks, hat-pegs, brackets and similar fixtures; …: Hat-racks, hat pegs, brackets and similar fixtures, and parts thereof.” |
| Item: The merchandise under consideration is iron Christmas wreath hangers. These metal hangers have an over-the-door hook on top and a rounded hook on the bottom that can be used to hang wreaths or other items. Item 1 is a silver hanger with a decorative silver snowflake design in the center. Item 2 is a bronze hanger with a decorative bronze reindeer design in the center. Item 3 is a black hanger with a square MDF sign in the center featuring a black and white checkered pattern and the words “Merry Christmas.” Item 4 is a red hanger with a decorative MDF sign in the center that features the words “Jesus is the Reason for the Season.” Item 5 is a brown hanger with a decorative MDF sign shaped like a Christmas tree in the center that features a cardinal, snowflakes, the word “Peace” and includes pine needles and 2 pinecones. |
| Reason: N/A |
| Ruling Date: April 17, 2025 |
N346992: The country of origin of a comforter, unquilted sham, and comforter set; 19 CFR 102.21(c)(2)
| Origin: Pakistan |
| Item: The first article, the English Forest Natural Comforter, is made of 100% cotton woven fabric, and it is filled with a 100% polyester fiber batting. The comforter face displays an arboreal forest print, and the comforter back displays small grey diamonds on an off-white background. There is no embroidery, lace, braid, edging, trimming, piping exceeding 6.35 mm or applique work. The comforter will be either printed or dyed but, not both. The second item is unquilted cotton pillow shams. The pillow shams have a flanged border and an opening at the back of each sham where two panels slightly overlap in the center. The opening is closed with self-fabric ties. The pillow sham face displays an arboreal forest print, and the pillow sham back displays small grey diamonds on an off-white background. There is no embroidery, lace, braid, edging, trimming, piping exceeding 6.35 mm or applique work. The shams will be either printed or dyed but, not both. The third article, the English Forest Natural Set, is available in three options: The English Forest Natural Twin Comforter Set, which consists of 1 quilt and 1 sham, the English Forest Natural Full/Queen Comforter Set, which consists of 1 quilt and 2 standard shams, and the English Forest Natural King Comforter Set, which consists of 1 quilt and 2 King shams. In Pakistan, the yarn is woven into cotton face and back fabrics. The fabrics are exported to China. In China, the cotton face and back fabrics are dyed or printed. The fabrics are cut and sewn to form the comforter and unquilted pillow shams. The comforter is stuffed with Chinese-sourced 100% polyester batting and sewn shut. The comforter and unquilted shams are packaged and exported to the United States. |
| Reason: Since the comforters’ face and back fabrics are woven in Pakistan, and no other fabrics were used in the production of the comforters, the country of origin of the comforters is conveyed by the fabric-making process in Pakistan, so pursuant to 19 CFR 102.21(e)(2)(ii), the origin of the comforters is Pakistan. |
| Ruling Date: April 17, 2025 |
N347011: The country of origin of a gold, diamond, and gemstone ring
| Origin: Thailand |
| Item: A gold ring is cast in Thailand. The casting is then sent to China. In China, the casting undergoes minor finishing (polishing, setting, and packaging) before being sent to the United States. The ring is produced in a nine (9) step process: Step 1: Designing the Ring Setting. This is performed in the United States. Step 2: Creating the Wax Model. This is performed in Thailand. Step 3: Spruing and Investing. This is performed in Thailand. Step 4: Wax Burnout (Lost-Wax Process). This is performed in United States. Step 5: Metal Casting. This is performed in Thailand. Step 6: Cooling and Mold Breakout. This is performed in Thailand. Step 7: Sprue Cutting. This is performed in Thailand. Step 8: Logo Engraving. This is performed in Thailand. Step 9: Stone Setting & Final Finishing. This is performed in China. Step 9: Packaging & Tagging. This is performed in China. |
| Reason: The operations that have taken place in China do not effect a substantial transformation. Therefore, the country of origin of the ring is Thailand. |
| Ruling Date: April 17, 2025 |
N347026: The tariff classification of Turmeric Roll Cleanser Party Kit
| HTS: 3304.99.5000, free, “Beauty or make-up preparations and preparations for the care of the skin (other than medicaments), including sunscreen or sun tan preparations; manicure or pedicure preparations: Other: Other: Other.” |
| Item: The item under consideration is described as a Turmeric Roll Cleanser Party Kit. The kit is imported in a box containing 10 plastic containers, 10 lids, 10 labels, 2 instruction cards and the ingredients necessary to make 10 individual skin cleansers. The ingredients include ground almonds, kaolin, a mix of sunflowers in glycerine and aloe vera, glycerine, fragrance, witch hazel extract, and turmeric powder. The only ingredient not included in the kit is water. It will be shipped to retail stores for use during customer booked events as a product making activity. To make the cleanser all the ingredients are placed into a bowl with water, mixed together, and portioned out into the plastic containers. |
| Reason: The unassembled Turmeric Roll Cleanser Kit has the essential character of a skin cleanser. |
| Ruling Date: April 17, 2025 |
N347100: Classification and country of origin determination for a quilted outdoor blanket; 19 CFR 102.21(c)(4)
| HTS: 6307.90.9891, 9903.01.24, 9903.01.63, 9903.88.15, 7% + 20% + 125% + 7.5%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Origin: China |
| Item: An “Outdoor Blanket,” is designed and intended to be used outdoors to sit or lay on while camping, picnicking, or attending outdoor activities. The manufacturing operations for the quilted outdoor blanket are as follows: In China: Face side: polyester fabric is woven, printed, and shipped in rolls to Cambodia. Back side: polyester fabric is woven, dyed, coated, and shipped in rolls to Cambodia. Webbed strap, binding fabric, and webbed loops are woven, dyed, and shipped in rolls to Cambodia. Velcro and zipper are formed and shipped to Cambodia. In Cambodia: 100% polyester nonwoven batting is produced. Polyester sewing thread is produced. Face side fabric, nonwoven batting, and back side fabric are quilted together. Cut the quilted fabric and sew the binding to form the body of the blanket. Cut the fabric and sew the pocket to the blanket. Cutting and sewing of the Velcro, webbed strap, and webbed loops. Completed outdoor blanket is packaged in a plastic bag with a paper band, packaged in a carton, and shipped to the United States. |
| Reason: The most important manufacturing process occurs at the time of fabric making. Basing the country-of-origin determination on the fabric making process, and not the assembly process, carries out the clear intent of Section 334 as expressed in Section 334 (b)(2) and Part 102.21(c)(2). The quilted outdoor blanket consists of two outer shell fabrics (woven in China) and a batting fabric (formed in Cambodia). While all of the fabrics are important to the construction of the outdoor blanket, in this case, it is the outer shell fabrics that are most important as they provide the aesthetic appeal to the item. Accordingly, the fabric-making process in China, where the outer shell fabrics are formed, constitutes the most important manufacturing process and the country of origin of the quilted outdoor blanket is China. |
| Ruling Date: April 17, 2025 |
N347176: The country of origin of a Bit & Holder Set with Carabiner and a Bit Holder Set with Carabiner
| Origin: Vietnam and China |
| Item: The two items under consideration are identified as a Bit & Holder Set with Carabiner and a Bit Holder Set with Carabiner. The Bit & Holder Set with Carabiner consists of six different driver bits with standard 1/4" shanks and six bit holders that can receive standard 1/4" shanked bits. The Bit Holder Set with Carabiner is the same as the first item, except that it does not include the six bits. It is intended for the user to supply their own bits for the holders. Each item will be produced in Vietnam and China, under two production scenarios: Production Scenario for the Bit & Holder Set with Carabiner 1: In Vietnam, raw steel is cut, stamped or cold forged into the final shape, size and form of each of the bits, including the final shape and form of the driving end of the bits. The bits also have their final 1/4" drive shank size and shape formed in Vietnam. Also in Vietnam, raw aluminum is formed into the three major bit holder parts. The fully formed bits and holder parts are then sent to China where the bits undergo heat-treatment and surface-treatment. The three holder parts are surface-treated and then assembled by pressing them together with a Chinese origin spring and ball bearing. The six bits are inserted into the holders, and key rings are used to attach the bit holders to a Chinese origin carabiner before export to the United Sates. Production Scenario 2 for the Bit Holder Set with Carabiner: In Vietnam, raw aluminum is formed into the three major bit holder parts. The holder parts are then sent to China. In China, the three holder parts are surface treated then assembled by pressing them together along with a Chinese origin spring, ball bearing, and key ring. Key rings are used to attach the bit holders to a Chinese origin carabiner before export to the United States. |
| Reason: In regard to the Bit & Holder Set with Carabiner, the cutting, stamping and cold forging of the raw steel in Vietnam into the final shape and form of the bits impart the essence and essential function of the final item (i.e., turning a nut, screw or socket). We also note that in Vietnam, the final ¼” drive shank size and shape are formed. Based on the provided descriptions and pictures of the assembly and finishing operations performed in China, the bits are not substantially changed so as to transform them into new articles with a different name, character, or use. Therefore, the country of origin of the Bit & Holder Set with Carabiner is Vietnam. Regarding the country of origin of the Bit Holder Set with Carabiner, only the three components of each holder are made in Vietnam. These three holder components are neither clearly recognizable as a bit holder nor are they in the final form of a finished bit holder after the production processes performed in Vietnam. The three holder parts are then sent to China where they are pressed together and assembled with a Chinese origin spring and ball bearing. The finished holder uses the spring and ball bearing to hold the shank of a bit. Therefore, the three bit holder components are substantially transformed in China into a finished bit holder. Consequently, the country of origin of the Bit Holder Set with Carabiner is China. |
| Ruling Date: April 17, 2025 |
N347254: The tariff classification of steel delivery carts from Vietnam
| HTS: 8716.80.5090, 9903.01.25, 3.2% + 10%, “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Other vehicles: Other: Other: Other.” |
| Item: The item under consideration has been identified as a steel delivery cart. The cart has the following specifications: Steel cart (53” deep x 18” wide x 39" tall) 6-wheels (no wheels/caster attached at time of import) Painted/Powder coated They will be imported for commercial sale, and this first shipment will contain forty (40) carts. |
| Reason: N/A |
| Ruling Date: April 17, 2025 |