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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N348886: The tariff classification of a battery housing from Serbia
| HTS: 8507.90.8000, 9903.94.05, 9903.01.33 3.4% + 10% + 25%, “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Parts: Other.” |
| Item: The merchandise under consideration is identified as a battery housing and is the bottom enclosure for an electric vehicle battery assembly. It is created using a die casting process from an aluminum alloy meeting the European standard EN AC-43500. The housing is contoured to a vehicle chassis and has shallow pockets, recessed trays, mounting points, and other open spaces that collectively hold and protect a battery module subassembly that is installed post-importation. Afterwards, an upper panel assembly (that is not part of this request) is installed and the finished battery assembly is mounted inside a vehicle. |
| Reason: N/A |
| Ruling Date: May 29, 2025 |
N348913: The country of origin of heat pump units
| Origin: India |
| Item: The products at issue are heat pump units. The rooftop heat pump units are referred to as air-conditioning units and are intended to be installed on the roof of recreational vehicles, caravans, pop-top caravans and camper trailers. The units, which are powered using an alternating current power supply, are designed to change the temperature and humidity levels within a vehicle while stationary. The heat pumps consist of a shroud cover and a bottom plate assembly that enclose a compressor, an evaporator, a condenser, and other components that contribute to the cooling process. With respect to origin, there are three origin scenarios for the heat pump units. For scenarios one and two, the final assembly occurs in China, and for scenario three, the final assembly occurs in India. Prior to the final assembly, the compressor is assembled in India in scenario one and is assembled in China for scenarios two and three. |
| Reason: Based on the proposed manufacturing scenarios, the final assembly operations, which occur in either China or India, do not result in a substantial transformation. The components are installed using processes that are rather simple. As such, the origin of the cooling components determines origin, which consist of the evaporator, condenser and compressor, as the function of air conditioning units is to change the temperature and humidity levels within a space. In scenario one, the cooling components are from India. Accordingly, the country of origin of the heat pumps for scenario one is India. However, in scenarios two and three, the cooling components do not originate from the same country. In these instances, CBP has determined that the origin of air conditioning units is determined by the majority of the cooling components. |
| Ruling Date: May 29, 2025 |
N349083: The tariff classification of a pump module from Canada
| HTS: 8413.70.2025, free, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Other centrifugal pumps: Other: Other: Single-stage, single-suction, frame-mounted: With discharge outlet 7.6 cm or over in diameter.” |
| Item: The 232 Low Pressure Separator Pump Module is a module installed at the Nanushuk Processing Facility in Alaska. The module is comprised of two Low Pressure Separator Crude Pumps, two Low Pressure Separator Produced Water Pumps, pump motors, pump seals, and a heating, ventilation, and air conditioning (HVAC) system that maintains the temperatures required to meet the operational needs of the pumps and other equipment. The pumps and other components are enclosed in a building and connected using pipes that incorporate valves and instrumentation controls. The principal function of the module is to pump fluids to separately imported modules, which is achieved by the crude pumps and the water pumps. The crude pumps circulate separated oil to the Treater Module and feature discharge connections that measure ten inches in diameter. The water pumps circulate water to the Produced Water Separator Module and feature discharge connections that measure three inches in diameter. These centrifugal pumps are vertically mounted, and are configured as single stage, suction type of pumps. |
| Reason: N/A |
| Ruling Date: May 29, 2025 |
N349122: The tariff classification of Smart Watches from China
| HTS: 8517.62.0090, 9903.01.24, 9903.01.32, 9903.88.15, free + 20% + 10% + 7.5%, “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network)…: Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” |
| Item: The two items concerned are consumer-grade smartwatches from China: 1. The Indestructible Smartwatch (Model: Njord-watch-pro) 2. The APEX Smartwatch (Model: apex-smartwatch-orange) Both are manufactured by Wei Yu Long Industries (Shenzhen, China) and imported by Njord Gear Co. (Canada). These smartwatches are Bluetooth-enabled wearables intended for health tracking and smartphone notification relay. They require Bluetooth pairing to a mobile phone for all functions. The Indestructible Smartwatch (Model: Njord Watch Pro) is a wrist worn Bluetooth-enabled electronic device designed exclusively for use as a companion accessory to a host smartphone. This device does not contain nor support any standalone communication, navigation, or internet functions. It operates solely via Bluetooth Low Energy (BLE) connectivity and is not functional without pairing to a smartphone. This smartwatch features/incorporates: A 1.32-inch IPS full-color capacitive touchscreen display, enclosed in a reinforced polymer housing with a metal bezel. |
| Reason: N/A |
| Ruling Date: May 29, 2025 |
N349243: The tariff classification of handbag charms from an undetermined country of origin
| HTS: 7117.90.9000, 11%, “imitation jewelry: other: other: valued over 20 cents per dozen pieces or parts: other: other.” |
| Item: Handbag charms constructed predominantly of bovine leather with zinc alloy spring ring and tubular end caps. The handbag charms are marketed and intended to be sold solely for decorative purposes. They are intended to be attached to handbags and similar articles to decorate or further embellish them. |
| Reason: N/A |
| Ruling Date: May 29, 2025 |
N349251: The tariff classification of a liquid chromatography device from Japan
| HTS: 9027.20.5060, 9903.01.25, free + 10%, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Chromatographs and electrophoresis instruments: Electrical: Liquid chromatographs.” |
| Item: The item under consideration is described as the Eicom High-Performance Liquid Chromatography with Electrochemical Detection (HPLC-ECD) System, which is designed for sensitive and selective analyses of electroactive compounds. It combines HPLC’s separation capability with the detection sensitivity of electrochemical methods. The system is used in neuroscience, pharmacology, and related research fields. The components are non-biological and not intended for human use or for diagnostics of human or animal disease. The device measures 290 mm wide by 380 mm deep by 435 mm high and weighs 23.2 kg. This HPLC-ECD system is a high-performance liquid chromatography system using an electrochemical detector. |
| Reason: N/A |
| Ruling Date: May 29, 2025 |
N348299: The tariff classification and country of origin of Frozen Cod, Pollock and Salmon Fillets
| HTS: (Cod) 0304.71.1000, 9903.01.25, free + 10%, “Fish fillets and other fish meat (whether or not minced), fresh, chilled or frozen: Frozen fillets of the families of Gadidae: Cod (Gadus morhua, Gadus ogac, Gadus macrocephalus): Skinned, whether or not divided into pieces, and frozen into blocks each weighing over 4.5 kg, imported to be minced, ground or cut into pieces of uniform weights and dimensions.” (Frozen Alaskan Pollock Fillets) 0304.75.1000, 9903.01.25, free + 10%, “Fish fillets and other fish meat (whether or not minced), fresh, chilled or frozen: Alaska pollock (Theragra chalcogramma): Skinned, whether or not divided into pieces, and frozen into blocks each weighing over 4.5 kg, imported to be minced, ground or cut into pieces of uniform weights and dimensions.” (Frozen Pink Salmon fillet) 0304.81.1000, 9903.01.25, free + 10%, “Fish fillets and other fish meat (whether or not minced), fresh, chilled or frozen: Frozen fillets of other fish: Pacific salmon (Oncorhynchus gorbuscha): Skinned, whether or not divided into pieces, and frozen into blocks each weighing over 4.5 kg, imported to be minced, ground or cut into pieces of uniform weights and dimensions.” |
| Origin: China |
| Item: Cod (Gadus macrocephalus), Pink Salmon (Oncorhynchus gorbuscha) and Alaskan Pollock (Theragra chalcogramma) which are wild caught in the Gulf of Alaska by U.S.-flagged vessels. The fish products are shipped to China for further processing. In China, the fish products are thawed, cleaned, filleted, skinned, trimmed and the pin bones are removed. The skinless fillets are placed on individual quick-freezing (IQF) trays, quick frozen, portioned, weighed, glazed, individually vacuum packed and refrozen in polyvinyl bags, and packed into export cases for shipment to the United States. The cod, pollock and a portion of salmon fillets are packed in 2-pounds bags, 10 per case. Another portion of salmon fillet is packed in 1-pound bags, 10 per case. |
| Reason: The fish is harvested in the United States then processed in China (i.e., thawed, filleted, pin-bone removed, skinned), refrozen, and exported to the United States. The finished product is substantially transformed due to the processing performed in China. The country of origin is China. |
| Ruling Date: May 28, 2025 |
N348301: The tariff classification and Country of Origin of golf balls
| Origin: Korea and China |
| Item: In the first scenario, A. Corp, a parent company based in Korea, imports the raw material “core” for golf balls from its subsidiary in China. The golf ball core is in an uncoated state where the raw materials are mixed and cut, heat and pressure applied and buffed. The item is still not suitable to be used in the sport of golf. The “raw fabric” is then shipped to A. Corp’s factory in Korea where it will go through a series of processing steps including cover extrusion, injection molding, base coating, marking, final inspection and packaging, to produce the finished golf ball which is then packaged and sent to the U.S. In the second scenario, A. Corp’s Chinese subsidiary imports the raw material “golf ball core” for the golf balls from Vietnam. The golf ball core is in an uncoated state where the raw materials are mixed and cut, heat and pressure applied and buffed. The item is still not suitable to be used in the sport of golf. The “raw fabric” is then shipped to A. Corp’s factory in China where it will go through a series of processing steps including cover extrusion, injection molding, base coating, marking, final inspection and packaging, to produce the finished golf ball which is then packaged and sent to the U.S. |
| Reason: The further processing in the second country results in a substantial transformation in that the raw fabric was transformed into a functioning golf ball. In case 1, the country of origin would be Korea where in case 2 the country of origin would be China. |
| Ruling Date: May 28, 2025 |
N348330: The tariff classification of ready-to-eat snack mixes from Thailand
| HTS: 2008.99.9190, 9903.01.25, 6% + 10%, “which provides for other edible parts of plants, otherwise prepared or preserved ... other ... other.” |
| Item: The subject merchandise is described as ready-to-eat snack mixes containing a blend of rice crackers and vegetables. Each sticky rice chip is round in shape, light and airy, while consisting of a crunchy texture. The vegetables retain their natural shape, and similar to the sticky rice chips, are light and airy, and have a crunchy texture. The individual component of the sticky rice chips are said to be prepared by combining mochi rice, sugar, watermelon juice and salt, mixing, then shaping via a mold which is then deep fried in oil until crispy. The characteristic vegetables are cleaned, cut to small bite-sizes, weighed, then vacuum fried. This gentle frying method is described as a process where the food is fried in oil under low pressure (vacuum conditions) which helps to preserve the natural color, flavor and nutrients of the food. The sticky rice chips and vacuum fried vegetables are mixed in large vats then seasoned with various spices, prior to packaging in 1.06 oz. aluminum bags, which will be packed in 12-count corrugated cardboard shipping cartons, encompassing 144 cartons per pallet. |
| Reason: In the case of the ready-to-eat snack mixes at issue, since no ingredient imparts the essential character of the mixture, in accordance with GRI 3(c), the classification would be provided from the item last in tariff, which in this case are the sticky rice chips for both products, respectively. |
| Ruling Date: May 28, 2025 |
N348451: The country of origin of Benzonatate Capsules, USP in dosage form
| Origin: Taiwan |
| Item: Benzonatate, imported in 100 mg and 200 mg capsules, is a non-narcotic antitussive agent. It is indicated for the symptomatic relief of cough. The active pharmaceutical ingredient (API), Benzonatate, is manufactured in Taiwan and that the finished capsules in dosage form are made in China. In China, the Benzonatate will be mixed with various inactive ingredients to produce the final Benzonatate capsules in dosage form. |
| Reason: The mixing of the active ingredient Benzonatate (made in Taiwan) with the inactive ingredients into the final dosage Benzonatate capsules in China does not result in a substantial transformation and the country of origin will be Taiwan. |
| Ruling Date: May 28, 2025 |