Recent CBP NY Rulings

June 18, 2025 |Customs 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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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.

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N348151: The tariff classification of maskless UV laser beam lithography systems from the Netherlands

HTS: 8486.20.0000, 9903.01.32, free + 10%, “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in Note 11(C) to this chapter; parts and accessories: Machines and apparatus for the manufacture of semiconductor devices or of electronic integrated circuits.”

Item: The PICOMASTER XF Series consists of five models of focused UV laser beam systems for semiconductor lithography and microelectronic/nanofabrication applications. The XF Series models employ a multi-beam laser to directly (i.e., without a photomask) draw or “write” patterns on the nanometer scale onto semiconductor devices and other photosensitive substrate materials. The XF Series models are designed for and principally used in semiconductor manufacturing (mask creation, direct writing on semiconductor materials), photonics (fabrication of optical components), LED manufacturing, flat panel display patterning, MEMS/NEMS (fabrication of micro/nano-electromechanical systems), microfluidics, and RF device component creation.

Reason: N/A

Ruling Date: May 9, 2025

N347734: The tariff classification of Peritoneal Dialysis (PD) solutions of Extraneal® (icodextrin) and Dianeal® (dextrose), in dosage form, from Mexico

HTS: 3004.90.9270, 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: Other: Other: Preparations primarily affecting the electrolytic, caloric or water balance: Other.”

Item: The Peritoneal Dialysis (PD) solutions imported in ultrabags are used to remove excess fluid, correct electrolyte problems, and remove toxins in those with kidney failure. Extraneal (icodextrin) is indicated for the management of kidney failure in patients requiring long-term kidney replacement therapy. Dianeal (dextrose) is indicated for the management of acute or chronic renal failure.

Reason: N/A

Ruling Date: May 8, 2025

N347911: The tariff classification of a focused ion beam nanofabrication system from Germany

Item: The VELION system is a focused ion beam (FIB) lithography and patterning/milling tool designed primarily for use in semiconductor manufacturing, as well as other applications requiring unique patterning techniques. It is capable of processing full 4-inch wafers and is used in semiconductor development and production processes. The machine employs a focused ion beam to directly draw patterns on the nanometer scale onto semiconductor devices and other substrates. It is also used for direct thin-film patterning by milling functional layers, as well as ion beam fabrication of nanostructures by milling, ion-induced etching, implantation, and deposition. Within the same housing, the VELION includes a scanning electron microscope (SEM) column with a detector for cross-section analysis of semiconductors.

Reason: N/A

Ruling Date: May 8, 2025

N348066: The country of origin of an LED Mini Light Bar

Origin: Vietnam

Item: The item under consideration has been identified as a 15 Inch Octagonal LED Mini Light Bar. The LED light bar is used on the Snowplow Truck, Work Truck, Pickup Trucks, and Trailers. It is designed to be placed outside on top of a work truck’s cab as a signaling device to other vehicles/pedestrians to proceed with caution around this vehicle. The LED light bar consists of a lens, reflector, printed circuit board assembly (PCBA) light board containing 68 LEDS, a sealing ring, plastic housing/frames, as well as a magnetic base. The light bar also includes a 15 ft power cord with an accessory power plug with an on/off switch. The magnetic base allows the light bar to attach to the cab, or it can be permanently attached with the mounting feet. The PCBA light boards are manufactured in Vietnam via Surface Mount Technology process. The PCBA is populated with an IC chip, as well as various fuses, diodes, capacitors, varistors, etc.

Reason: Although some of the components, such as the lens and refractors, are produced in China and the manufacturing process occurs in China, the LED PCBA is the single most important and critical component. The assembly in China is a simple assembly that involves manually inserting the PCBA board in the housing and snapping the housing onto the magnetic base. It possesses the predetermined end-use for the making of the LED mini light bar. The use of the article has already been pre-determined upon importation from Vietnam to China. The assembly operations performed in China do not substantially transform these Vietnamese originating components into Chinese products. The assembly in China of the additional individual components to produce the finished LED mini light bar does not create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into China. The key component of the LED mini light bar, e.g., the LED PCBA, does not lose its individual identity as a result of the assembly process in China.

Ruling Date: May 8, 2025

N347665: The tariff classification of Ascorbic Acid (CAS No. 50-81-7) in bulk powder form, from China

HTS: 2936.27.0000, 9903.01.24, 9903.01.32, free + 20% + 125%, “Vitamin C (Ascorbic acid) and its derivatives.”

Item: Ascorbic Acid, also known as Vitamin C is a water-soluble vitamin essential for various bodily functions and increases resistance to infections. It is used to prevent and treat scurvy, a disease caused by vitamin C deficiency. The Ascorbic Acid is U.S. Pharmacopeia (USP) grade.

Reason: N/A

Ruling Date: May 7, 2025

N347759: Country of origin determination for Duvet set; 19 CFR 102.21(c)(5)); last country where an important assembly or manufacturing process occurred

Origin: Vietnam

Item: The subject merchandise, described as a Duvet Set, consists of a duvet cover and two pillow shams. The duvet cover and shams both have a face of 70% rayon and 30% linen dyed woven fabric. The back of the duvet cover and shams is a 100% cotton dyed woven fabric. The front and back panels of each piece are sewn together with a strip of face fabric with raw edges inserted into the seam. This strip of fabric extends from the seam and, through laundering, a decorative frayed edge is created. Both the shams and duvet cover include an opening on the back with a zipper closure. The duvet cover and shams are imported in Full/Queen and King sizes. The manufacturing operations for the duvet cover and shams are as follows: In China: Face fabric for duvet cover and shams is woven, dyed and exported to Vietnam. In Vietnam: Back fabric for duvet cover and shams is woven and dyed. Face and back fabrics are cut. Duvet cover and shams are sewn and assembled into the finished duvet cover and sham. Finished duvet covers and shams are packed and shipped to the United States.

Reason: Where the country of origin of a textile or apparel product cannot be determined under paragraph (c) (1), (2), (3) or (4) of this section, the country of origin of the good is the last country, territory, or insular possession in which an important assembly or manufacturing process occurred. Accordingly, in the case of the subject duvet covers and shams, the country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Vietnam, where the articles are assembled.

Ruling Date: May 7, 2025

N347840: The country of origin of faucets

Origin: Vietnam

Item: The four styles of faucets at issue are the MACKSJÖN centreset washbasin mx tp 4 (MACKSJÖN tp 4), the MACKSJÖN widespread washbasin mx tp 8 (MACKSJÖN tp 8), the MACKSJÖN kit mx tp pullout with spray (MACKSJÖN pullout with spray) and the MACKSJÖN kit mx tp pulldown with spray (MACKSJÖN pulldown with spray). The faucets are used to control the flow of water released into a sink. The faucets are comprised of Chinese sourced components, hoses manufactured in Vietnam, and a subassembly manufactured in Vietnam. The final assembly of the faucets occurs in China. The cartridge valve subassembly, which controls the flow of water, is the subassembly that is manufactured in Vietnam.

Reason: The final assembly processes completed for the four faucets are rather simple and do not constitute a substantial transformation. The processes performed in China do not change the shape, character, or predetermined use of the Vietnamese produced valve subassemblies are the essential component of faucets. Therefore, as the country of origin of the cartridge valve subassemblies is Vietnam, the country of origin of the faucets is Vietnam.

Ruling Date: May 7, 2025

N347909: The tariff classification of an Electron Beam Lithography System from Germany

Item: The VOYAGER product is an electron beam lithography (EBL) nanolithography tool, also referred to as an e-beam writer. The VOYAGER is specifically designed and principally used for lithograph patterning of semiconductor devices. It is also suitable for use in the fabrication of integrated circuits, photonic components, microelectromechanical systems (MEMS), and producing semiconductor device prototypes and small-batch specialized components. Highly focused electron beams are employed to directly (without a mask) draw patterns on the nanometer scale onto semiconductor devices and other resist-coated substrates. The VOYAGER operates with a beam energy range between 10-15 kV. The core system components are: (1) electron beam column; (2) electron optics system; (3) pattern generator; (4) laser interferometer X-Y-Z positioning stage; (5) vacuum system; and (6) control system consisting of a Window 10-based workstation running Raith NanoSuite and optional ErgoFlow software. Also included are the system housing and environmental controls consisting of a thermal and acoustic shielding enclosure for the EBL system, separate enclosures for the electronic control systems, and integrated chillers to control the temperature of system components. The machine’s chamber measures 500mm x 440mm x 300mm (W x D x H).

Reason: N/A

Ruling Date: May 7, 2025

N348117: The tariff classification of a man’s waterproof boot from China

HTS: 6405.90.9060, 9903.01.24, 9903.01.63, 12.5% + 20% + 125%, “Other footwear: Other: Other: Other.”

Item: The merchandise under consideration is identified as a “man’s ankle mud boot.” It is an above-the-ankle man’s waterproof boot with two pull loops at the front and back of the topline. The external surface area of the boot’s upper is comprised mostly of rubber/plastic and textile gore on the lateral and medial sides. The rubber/plastics lug outer sole has a thick application of leather flocking covering most of the outer sole that contacts the ground. The leather material is visible and tactile on the surface and completely obscures the rubber/plastics underneath. The constituent material of the outer sole is considered “other than rubber/plastics.”

Reason: N/A

Ruling Date: May 7, 2025

N348614: The tariff classification of Christmas tree ornaments and photo frames from China

HTS: (item numbers P1201, P1203, P1209, and P1212) 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 numbers P1208 and P1204) 8606.30.0000, 9903.01.24, 9903.01.63, 9903.88.03, 2.7% + 20% + 125% + 25%, “bells, gongs and the like, nonelectric, of base metal … photograph, picture or similar frames; mirrors; and parts thereof.”

Item: Six items described as Christmas ornaments made of cast zinc which feature a built-in loop with an extra ring threaded with a permanently attached man-made textile ribbon hanging loop with bow. All items have a front facing design only, the back is plain. Two of the items have a removable back designed to display photos. These items are said to be marketed, advertised, and sold specifically for Christmas. Each item will be sold separately, packaged on a retail blister card.The first item is identified as CARD ORNAMENT DOG WREATH-GOLD/GREEN, item number P1201, which depicts a golden dog face with a decorated Christmas wreath. The ornament measures approximately 1 .50” x 1.57”. The second item is identified as CARD ORNAMENT PUPPY 1ST CHRISTMAS SIL/CRYS, item number P1203, which depicts a heart shape with a paw print inset with glass “crystal” stones. The ornament measures approximately 1.65” x 1.30”. The third item is identified as CARD ORNAMENT FRENCH BULLDOG-GOLD/GREEN, item number P1209, which depicts the image of a French Bulldog’s face in a cut-out circle. The ornament measures approximately 1.89” x 1.81”.The fourth item is identified as CARD ORNAMENT PAW-GOLD/CRYSTAL, item number P1212, which depicts a paw print with inset glass “crystal” stones set in a cut-out circle. The ornament measures approximately 1.47” x 1.44”. The fifth item is identified as CARD ORNAMENT SNOWFLAKE PHOTO-SIL/CRY, item number P1208, which is a zinc photo frame in the shape of a snowflake with glass “crystal” stones inset embellishing the frame. It measures approximately 2.24” x 2.24”, has a removable backing, and is designed to hold and display a small photograph. The sixth item is identified as CARD ORNAMENT DOGHOUSE PHOTO FRAME-SIL/BLUE, item number P1204, which is a zinc photo frame in the shape of a doghouse with small glass “crystal” stones outlining the door. It measures approximately 57 mm x 52 mm, has a removable backing, and is designed to hold and display a small photograph.

Reason: N/A

Ruling Date: May 7, 2025