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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N348156: The tariff classification of a piezoelectric ignitor from China
| HTS: 9613.80.2090, 9903.01.24, 9903.01.25, 9903.88.15, 3.9% + 20% + 125% + 7.5%, “[c]igarette lighters and other lighters, whether or not mechanical or electrical, and parts thereof other than flints and wicks: [o]ther lighters: [o]ther: [e]lectrical: [o]ther.” |
| Item: The product under consideration is an igniter that is used in hand-held propane torches to initiate flame by applying voltage through an air gap in the flow of premixed fuel and air. The voltage is generated by a piezoelectric quartz that is hit by a small hammer contained within the plunger. |
| Reason: N/A |
| Ruling Date: May 15, 2025 |
N348168: The classification of two round tables from China
| HTS: 9403.89.6015, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 125% + 25%, “Other furniture and parts thereof: Furniture of other materials, including cane, osier, bamboo or similar materials: Other: Other: Other household.” |
| Item: The two subject tables each have a white marble tabletop (natural stone) atop an MDF base. The frame, legs, and stretcher are made of cold rolled iron, and the frame and legs have a gold-colored finish. The smaller and taller of the two tables is an end table with a round tabletop with a diameter of approximately 20". The table is approximately 20.5" high and weighs approximately 30 lbs. The larger and shorter of the two tables is a cocktail table with a round tabletop with a diameter of approximately 40". The table is approximately 14.6" high and weighs approximately 123 lbs. Each table is shipped in two boxes (tabletop and base packaged separately) and made in China. |
| Reason: The essential character of the two tables is imparted by its marble tabletops. |
| Ruling Date: May 15, 2025 |
N348185: The country of origin of panoramic sunroof assemblies
| Origin: China and South Korea |
| Item: The articles under consideration are panoramic sunroof assemblies, Panorama Sunroof NX4 (Model 1) and Sunroof Assembly NX4a MMH (Model 2), which are used in passenger vehicles. Each sunroof covers the entire roof of a vehicle and allows for ventilation and light control by tilting and sliding the roof panel. Model 1 consists of a tempered glass/infrared-blocking glass from China, and frame/rails (aluminum alloy and high-strength plastic), sealing components (rubber), and a motor from South Korea. The glass from China is shipped to South Korea where it undergoes an assembly process with the rest of the Korean components. The assembly process includes polyurethane (PU) encapsulation, inserting components into one another, fitting and assembling by screws or otherwise attaching, and oiling and greasing the components. Model 2 consists of a tempered glass/infrared-blocking glass, frame/rail components, and sealing components from South Korea, and a motor from the Philippines. The motor is shipped to South Korea to be assembled with the rest of the Korean components. The assembly process is similar to the process described above for Model 1. |
| Reason: The components to make the sunroof assemblies are complete and no substantial transformation occurs in South Korea. The processes performed in South Korea do not transform the glass into a new article, as the end-use of the glass is pre-determined. Since the glass is the main component of the sunroof assembly and the rest of the components are ancillary, the country of origin of the sunroof assembly will be the country of origin of the glass. As a result, the country of origin for Model 1 will be China and the country of origin for Model 2 will be South Korea. |
| Ruling Date: May 15, 2025 |
N348233: The tariff classification of a fireplace unit from South Africa
| HTS: 7321.81.5000, 9903.81.90, free + 25%, “Stoves, ranges, grates, cookers (including those with subsidiary boilers for central heating), barbecues, braziers, gas rings, plate warmers and similar nonelectric domestic appliances, and parts thereof, of iron or steel: Cooking appliances and plate warmers: Of gas fuel or for both gas and other fuels: Other: Other.” |
| Item: The merchandise is a fireplace unit identified as Emberglo 700 Insert. The fireplace unit is a freestanding, closed-combustion gas-burning fireplace for residential indoor use. It is rectangular in shape measuring 700 x 410 x 580 mm. The fireplace unit consists of a steel body with a high-temperature resistant glass front and side panel. The product features a venting opening for gas emissions (chimney) atop and a ceramic base with gas ports. |
| Reason: N/A |
| Ruling Date: May 15, 2025 |
N348329: The country of origin of paper plates
| Origin: Taiwan |
| Item: The product under consideration is molded, nesting paper plates. The plates measure 10 inches in diameter, and the paper from which they are made weighs 300 grams per square meter (gsm). The plates are printed and molded with an outer rim. The master paper rolls are from China. The master paper rolls are sent to Taiwan, where the paper is cut, printed, and molded into paper plates. |
| Reason: In Taiwan, the paper is die-cut to shape, printed, and molded into the plate shape. The totality of these operations constitutes a substantial transformation. Therefore, Taiwan is the country of origin of the paper plates. |
| Ruling Date: May 15, 2025 |
N348372: The tariff classification of wooden decorations from China
| HTS: (A) 911.91.4040, 4911.91.4040, free + 7.5%, “Pictures, designs and photographs: Printed not over 20 years at time of importation: Other: Other: Other.” (B) 9505.10.2500, 9903.01.24, 9903.01.25, 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: A Christmas Decoration which consists of an assortment of two styles of tabletop decorations made of medium-density fiberboard (MDF). The square shadowbox type decorations have a printed backdrop backing board and displays four small undecorated bottle brush trees made of plastic and iron attached to circular bases along the bottom of the box. The items measure approximately 8” (L) x 1.2” (W) x 8” (H). Both items are sold separately. Style A has a backdrop that reads “Holly Jolly Farm” with the words, “Sleigh Rides,” “Hot Cocoa,” and “Pine – Spruce – Fir” and “Cut & Carry.” Style B has a backdrop that reads “Locally Grown Christmas Trees” and “Pine – Spruce – Fir.” |
| Reason: N/A |
| Ruling Date: May 15, 2025 |
N348424: The country of origin of a track roller
| Origin: China |
| Item: The merchandise under consideration is identified as a track roller, which is an assembly used in the undercarriage of an excavator. Its main components include a central supporting shaft, a roller shell body, a seal group, and bushings. The function of the track roller is to support and distribute the weight of the excavator, and to guide the tracks as the machine moves. The subject track roller is assembled in Italy and requires a roller shell, a roller shaft, a plug, brackets, bushings, seal rings, O-rings, and pins. All the components are sourced from China except for the plug, O-rings, and pins, which are sourced domestically. The Chinese components arrive in Italy ready for assembly. The roller shell, bracket, and shaft are introduced into an automated assembly line in Italy where they are washed and dried. From here, the assembly process is separated into three sections. The first section has three stations and centers around the steel roller shell, which is described as the main wear-resistant surface where the track engages with the rollers. At the first station, bimetallic bushings are pressed into the roller shell. Next, a dedicated robot inserts the roller shaft through the central axis of the shell. At the last station, a gripper mechanism installs O-rings into grooves on opposite ends of the shaft. The next section prepares the subassemblies that are installed on the axial ends of the roller shell. An O-ring is installed onto a metal seal ring to create a seal group. The seal group is then pressed onto a bracket that functions as both a housing for the seal group as well as the mounting interface of the track roller to the frame of the machine. The subassemblies are then pressed onto each end of the roller shell assembly and pins are inserted to lock the brackets to the roller shell. Lastly, the assembly is filled with oil, the oil plug is installed, and the track roller is painted. |
| Reason: Nearly all of the components for the track roller are sourced from China. They arrive in Italy with a pre-determined end use as parts and components of a track roller. None of the Chinese components are substantially changed by the addition of the O-rings, pins, and plugs, nor are the assembly operations complex enough to transform the components into a new and different product. Therefore, the country of origin of the track roller is China. |
| Ruling Date: May 15, 2025 |
N348458: The tariff classification of a unisex sandal from Vietnam
| HTS: 6402.99.4960, 9903.01.25, 37.5% + 10%, “Other footwear with outer soles and uppers of rubber or plastics: Other footwear: Other: Other: Other: Other: Other: For women.” |
| Item: The merchandise under consideration is identified as GEI-1130 CV Unisex Casual Sandal. It is a unisex, below-the-ankle, open-toe/open-heel sandal. The upper’s external surface area is comprised of 57.9 percent rubber/plastic and 42.1 percent polyester textile. The sandal is secured via two adjustable straps with hook and loop closures located over the top of the foot. It has a rubber/plastics outer sole. |
| Reason: N/A |
| Ruling Date: May 15, 2025 |
N348490: The tariff classification of copper electrode blanks from the Netherlands and the country of origin of finished copper electrodes
| HTS: 8466.93.9885, 9903.01.25, 4.7% + 10%, “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for the machines; tool holders for any type of tool for working in the hand: Other: For machines of headings 8456 to 8461: Other: Other: Other: Other: Other: Other.” |
| Origin: Netherlands |
| Item: The items under consideration for classification (1) are described as copper electrode blanks used in the manufacture of finished copper electrodes to be incorporated into plasma arc cutting machine torches. At importation, the blanks are not ready for direct use but have undergone machining processes such that the blanks possess the dimensions and shape of a finished copper electrode. In the Netherlands, copper rods are intricately machined to precise shape and tolerances using a Swiss-style computer numerical control (CNC) lathe. The machining processes include turning, boring, threading, drilling, milling, and grooving. Upon importation, the copper electrode blanks are ready for coating, laser marking, and assembly with other components as preparation for direct use. The items under consideration for country of origin (2) are described as finished copper electrodes for incorporation into the torch of Hypertherm plasma arc cutting machines. During operation, the copper electrode is threaded into the plasma arc cutting machine torch body. As an electrical current flows through the copper electrode body and concentrates in the hafnium tip, it interacts with a stream of pressurized gas to generate a high-temperature plasma arc used to cut a metal workpiece. Copper is selected as the primary material due to its electrical conductivity and thermal dissipation properties. Furthermore, a hafnium tip is selected for its ability to maintain arc stability and extend the lifespan of the electrode. Manufacturing of the copper electrodes begins in the Netherlands where copper rod is precision-machined using a Swiss-type CNC lathe. After turning, boring, threading, drilling, milling, and grooving operations, the machined electrode blanks possess the approximate shape, dimensions and physical characteristics of the finished copper electrodes. After importation into the United States, the unfinished electrode blanks undergo surface finishing processes such as coating and laser marking and are assembled with O-rings and a hafnium insert. |
| Reason: (1) The copper electrode blanks satisfy the criteria for “blanks” as they are not ready for direct use but possess the approximate shape, dimensions, and outline of finished copper electrodes used in plasma arc cutting machine torches. The copper electrode blanks possess the substantial material form of the finished electrodes. Although unfinished, the physical and material qualities, particularly the inner and outer surface geometry, indicates that they are solely or principally designed for such use and neither suitable nor capable of another use. Under the authority of GRIs 1 and 2(a), the copper electrode blanks have the essential character of the finished copper electrodes and are classified accordingly. (2) No article emerges from the finishing and simple assembly processes in the United States with a new name, character, or use different from that possessed prior to processing. Although not ready for direct use, the copper electrode blank arrives in the United States in the pre-determined and dedicated physical form of a finished copper electrode. Since the copper electrode blank is of Netherlands origin and no substantial transformation takes place, the country of origin of the finished copper electrode is the Netherlands. |
| Ruling Date: May 15, 2025 |
N348500: The tariff classification of quick connector kits from China
| HTS: 8481.80.1050, 9903.01.24, 9903.01.25, 9903.88.03, 4% + 20% + 125% + 25%, “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: Hand operated: Of copper: Having a pressure rating under 850 kPa: Other.” |
| Item: The products at issue are the Kobalt 2-Way Brass Quick Connector Kit and the Kobalt Brass Quick Connector Set. The kits consist of items packaged together ready for retail sale and are used in irrigation and watering systems. The first kit consists of a two-way splitter with two quick connect plugs, a male quick connect plug, three male couplers, a female coupler, rubber washers and plastic components used for sealing. The splitter, which features individual shutoff valves in each outlet, allows users to control water flow between two separate hoses. The valves have a pressure rating under 850 kilopascals (kPas). The couplers facilitate a threadless attachment and detachment to hoses. The second kit consists of a male coupler, a female quick connect plug, two male quick connect plugs and a female coupler that features a shutoff valve with a pressure rating under 850 kPas. The connect plugs have no mechanical features and allow the user to attach or detach a hose or watering accessory. |
| Reason: N/A |
| Ruling Date: May 15, 2025 |