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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N347068: The tariff classification of a walker tray and a walker accessory bag from China
| HTS: 9021.10.0090, 9817.00.96, free, “orthopedic and fracture appliances, and parts and accessories thereof, other.” |
| Item: The products under consideration are a universal walker tray and a walker accessory bag that are specifically designed to be used with a standard mobility walker. The walker tray is made of polycarbonate plastic and measures 23 inches x 16 inches x 1 inch (Width x Depth x Thickness). The product comes in three transparent tinted color options: blue, purple, and black. The walker accessory bag is made of polyester and nylon textile materials. It is specially shaped and designed to be attached to a mobility walker. |
| Reason: Regarding the claim of duty-free treatment under 9817.00.96 for the walker accessory bag, it is specially shaped and designed to be attached to a walker. A secondary classification will also apply for the walker accessory bag in subheading 9817.00.96 as specially designed or adapted for the use or benefit of the permanently or chronically physically or mentally handicapped (except articles for the blind). |
| Ruling Date: April 23, 2025 |
N348064: The tariff classification of peat based growing media from Canada
| HTS: 2703.00.0000, free, “peat (including peat litter) whether or not agglomerated.” |
| Item: The five products under consideration are peat based growing media for commercial growers and consumers. Item 1 is PROMIX FPO AGTIV DEFEND. It consists of 65.11% sphagnum peat moss, 9.8% perlite, 22.41% coir, 0.17% wetting agent, 2.5% ground limestone and 0.01% Bacillus pumilus. Item 2 is PROMIX FPX AGTIV DEFEND. It consists of 86.91% sphagnum peat moss, 11% perlite, 0.21% wetting agent, 0.75% dolomite, 1.12% ground limestone and 0.01% Bacillus pumilus. Item 3 is PRO-MIX NFBO AGTIV DEFEND. It consists of 98.12% sphagnum peat moss, 0.38% wetting agent, 1.48% ground limestone and 0.01% Bacillus pumilus. Item 4 is PRO-MIX NFO AGTIV DEFEND. It consists of 98.05% sphagnum peat moss, 0.40% wetting agent, 1.54% ground limestone and 0.01% Bacillus pumilus. |
| Reason: N/A |
| Ruling Date: April 23, 2025 |
N348065: The tariff classification of peat based growing media from Canada
| HTS: 2703.00.0000, free, “peat (including peat litter) whether or not agglomerated.” |
| Item: The five products under consideration are peat based growing media for commercial growers and consumers. Item 1 is PROMIX O AGTIV DEFEND CORE BASE. It consists of 99.99% sphagnum peat moss and 0.01% Bacillus pumilus. Item 2 is PROMIX O AGTIV DEFEND Custom mix A. It consists of 98.45% sphagnum peat moss, 0.19% wetting agent, 1.35% ground limestone and 0.01% Bacillus pumilus. Item 3 is PROMIX O AGTIV DEFEND Custom mix B. It consists of 88.13% sphagnum peat moss, 10.27% perlite, 0.19% wetting agent, 1.40% ground limestone and 0.01% Bacillus pumilus. Item 4 is PROMIX O AGTIV DEFEND Custom mix C. It consists of 70.95% sphagnum peat moss, 26.78% coir, 0.16% wetting agent, 2.09% ground limestone and 0.01% Bacillus pumilus. Item 5 is PROMIX O AGTIV DEFEND Custom mix D. It consists of 69.39% sphagnum peat moss, 28.44% coir, 0.19% wetting agent, 0.63% dolomite, 1.33% ground limestone and 0.01% Bacillus pumilus. |
| Reason: N/A |
| Ruling Date: April 23, 2025 |
N347062: The tariff classification and country of origin of electric music interfaces
| HTS: 8543.70.9100, 9903.01.25, free + 10%, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Digital signal processing apparatus capable of connecting to a wired or wireless network for the mixing of sound.” |
| Origin: Vietnam or Malaysia |
| Item: The subject devices are constructed of multiple printed circuit board assemblies (PCBAs) within an enclosure. The PCBAs incorporate signal processors, field programable gate arrays (FPGA), and a central processing unit (CPU) among other electrical components. The electric music devices are used within music production installations in order to accept, mix, and convert the analog signals from various inputs (i.e. musical instruments, microphones). The devices are connected to a computer via the Thunderbolt or USB interface in order to allow the user to manipulate the sounds. However, the PCBAs within the device perform the processing and mixing functions through the various electrical components. This board is comprised of two digital signal processors, an FPGA, and the CPU processor among other electronic components. Per the information, this PCBA and its components perform the audio routing, mixing and signal processing that are the main functions of the finished device. In either Vietnam or Malaysia, this board is created through surface mount technology (SMT) that places and solders over 400 components. The finished board is then loaded with firmware and tested prior to being sent to China for final assembly. In China, the main digital board is combined with a top panel board of Chinese origin, which controls the switches, rotary dial, and LEDs on the front of the device. The boards are then assembled within the metal housing, which incorporates the various inputs and outputs on the rear. The finished device is then tested and packaged for shipment to the U.S. |
| Reason: The main digital board imparts the character of the finished device as it is the primary driver of the functionality of the device. Further, the assembly steps performed in China do not substantially transform the devices into new and different articles of commerce. The origin of the electric music interfaces listed below, will be Vietnam or Malaysia, dependent upon the creation of the main digital PCBA. |
| Ruling Date: April 22, 2025 |
N347066: The tariff classification and country of origin of electric music interfaces
| HTS: 8543.70.9100, 9903.01.25, free + 10%, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Digital signal processing apparatus capable of connecting to a wired or wireless network for the mixing of sound.” |
| Origin: Vietnam or Malaysia |
| Item: The subject devices are constructed of multiple printed circuit board assemblies (PCBAs) within an enclosure. The PCBAs incorporate signal processors, field programable gate arrays (FPGA), and a central processing unit (CPU) among other electrical components. The electric music devices are used within music production installations in order to accept, mix, and convert the analog signals from various inputs (i.e. musical instruments, microphones). The devices are rack mounted within the installation and connected through a desktop unit to a computer via the Thunderbolt or USB connection. This connection allows for expanded functionality of the desktop unit and allows for the user to manipulate the incoming sounds. The PCBA within the device performs the processing and mixing functions through the various electrical components.The manufacturing process begins with the creation of the main digital PCBA. This board is comprised of six digital signal processors, an FPGA, and the CPU processor among other electronic components. Per the information, this PCBA and its components perform the audio routing, mixing and signal processing that are the main functions of the finished device. In either Vietnam or Malaysia, this board created through surface mount technology (SMT) that places and solders over 700 components. The finished board is then loaded with firmware and tested prior to being sent to China for final assembly. In China, the main digital board is combined with multiple analog boards, of Chinese origin, that facilitate and control the connections, display, and various knobs and buttons. The finished boards are then assembled within the enclosure before the finished device is tested and packaged for shipment to the U.S. |
| Reason: Regarding the origin of the subject music interfaces, the main digital board imparts the character of the finished device as it is the primary driver of the functionality of the device. Further, the assembly steps performed in China do not substantially transform the devices into new and different articles of commerce. The origin of the electric music interfaces listed below, will be Vietnam or Malaysia, dependent upon the creation of the main digital PCBA. |
| Ruling Date: April 22, 2025 |
N347531: The tariff classification of a woman’s boot from China
| HTS: 6404.19.2060, 9903.01.24, 9903.01.63, 37.5% + 20% + 125%, “footwear with outer soles of rubber, plastics, leather and composition leather and uppers of textile materials: footwear with outer soles of rubber or plastics: other: footwear designed to be worn over, or in lieu of, other footwear as a protection against water, oil, grease or chemicals or cold or inclement weather: for women.” |
| Item: The constituent material of the upper is a plush faux fur and the outer sole consists of rubber/plastics. The boot measures approximately 14 inches tall and has a drawstring with a toggle closure around the topline. The inside of the boot, including the footbed, is completely lined with faux fleece over two layers of foamed rubber/plastics. The faux fleece, together with the foamed rubber/plastics, measure more than ½ inch, uncompressed. The boot is considered to be protective footwear for cold weather. |
| Reason: N/A |
| Ruling Date: April 22, 2025 |
N347563: Country of origin determination for duvet cover, pillow sham and duvet cover set; 19 CFR 102.21(c)(2); tariff shift
| Origin: Pakistan |
| Item: Item 1, is described as “English Forest Natural Full/Queen Duvet Cover” and is composed of 100% cotton printed woven fabric. The fabric is not napped. The duvet cover features a print design of foliage, branches and flowers on the front and a diamond print design on the back. In addition, the bottom of the cover features an opening with a nine-button closure. Item 2, is described as “English Forest Natural Cotton Standard Sham - Unquilted” and is composed of 100% cotton printed woven fabric. The fabric is not napped. Item 3, is described as “English Forest Natural Full/Queen Duvet Cover Set” consisting of a duvet cover and one or two unquilted cotton woven shams. The set consists of a duvet cover, described above under Item 1, and one or two unquilted cotton pillow shams, described under Item 2. The set will be packaged together under a white narrow-woven fabric ribbon printed with the Levetex Home brand logo. The manufacturing operations for the duvet cover and duvet cover set are as follows: In Pakistan, Cotton fibers are cleaned and spun into a yarn. Yarn is woven into cotton fabric. Fabric is exported to China in rolls. In China, fabric is either dyed or printed. Fabric is cut into panels to product size specifications. Polyester thread is formed and finished. Buttons are manufactured. The panels are sewn into a sham and duvet cover with the button closure. Duvet cover and duvet cover set are finished, packaged and exported to the United States. |
| Reason: As the fabrics comprising the duvet cover and the components of the duvet cover set are formed in a single country, which is Pakistan, and the country of origin is conferred in Pakistan. |
| Ruling Date: April 22, 2025 |
N347604: Country of origin determination for a knitted blanket; 19 CFR 102.21(c)(4); most important assembly or manufacturing process
| Origin: China |
| Item: A blanket consisting of three layers. The front of the blanket is a 100% polyester pile fabric knitted in a two-toned horizontal striped pattern. Each stripe is approximately 3 inches wide. The back of the blanket is a solid colored 100% polyester micro mink warp knit short pile fabric. Between these two layers is a layer of nonwoven fabric. The blanket has a knife edge and measures 60 × 70 inches. The item is designed to provide protection against the cold.The manufacturing operations for the “faux fur throw” are as follows: In China, a knit pile face fabric is formed. Knit pile micro mink backing fabric is formed. In Cambodia or Vietnam, a nonwoven lining is formed. In Cambodia, fabric cut and sewn. Completed blanket exported to the United States. |
| Reason: In the case of the subject merchandise, the most important manufacturing process occurs at the time of fabric making. Basing the country of origin determination on the fabric making process as opposed to the assembly process carries out the clear intent of Section 334 as expressed in Section 334(b)(2) and Part 102.21(c)(3)(ii). In the case of the subject throw, the fabric making process of the outer shell constitutes the most important manufacturing process; the inner nonwoven lining is very thin and comparatively insubstantial to the outer shell fabrics that provide ample warmth and comfort to the user. The outer shell of the throw is formed by two different fabrics knit in a single country. Accordingly, the country of origin of the throw is China. |
| Ruling Date: April 22, 2025 |
N347843: The tariff classification of cross-laminated timber panels from Austria
| HTS: 4418.82.0000, 9903.01.25, 3.2% + 10%, “Builders' joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and shakes: Engineered structural timber products: Cross-laminated timber (CLT or X-lam).” |
| Item: The product under consideration is cross-laminated timber panels. Cross-laminated timber panels are engineered structural timber products. The instant panels are constructed of Austrian spruce and have 3 to 8 layers of wood. The panels are used specifically for the construction of buildings. Each layer is constructed of multiple solid timber boards (wood sawn or chipped lengthwise, sliced, or peeled, with a thickness exceeding 6mm) that have been placed side by side, whether or not glued together. The wood grain of each layer is typically oriented at a right angle to the grain of adjacent layers. |
| Reason: N/A |
| Ruling Date: April 22, 2025 |
N347846: The tariff classification of wall hanging decorations from China
| HTS: (Halloween Canvas Advent Calendar) 9505.90.6000, 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: Other: Other.” (Christmas Advent Calendar) 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: Each item is hung on a wooden dowel with a thin cotton rope attached at both ends of the dowel to facilitate hanging on a wall. Both items have a plain back and measure approximately14 inches wide x 22 inches tall. The first style, Halloween Canvas Advent Calendar, consists of a wall-hanging decoration made of canvas. There are 31 pockets with embroidered numbers to count down to Halloween. A felt day marker is included in the shape of a mickey mouse head, that, when moved each day to the next pocket, counts down the days until Halloween. The item features a prominent banner at the top, with the words “Happy Halloween.” |
| Reason: N/A |
| Ruling Date: April 21, 2025 |