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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N348877: The tariff classification of electric motors from China
| HTS: 8501.32.2000, 9903.01.24, 9903.94.05, 9903.01.33, 9903.88.02, 2.9% + 20% + 10% + 25% + 25%, “Electric motors…: Other DC motors…: Of an output exceeding 750 W but not exceeding 75 kW: Motors: Exceeding 750 W but not exceeding 14.92 kW.” |
| Item: The first item under consideration is identified as the QS273 V3 Electric Car Wheel Hub Motor, which is a 72 V brushless DC (BLDC) electric motor having a single axle and a maximum power output of 26.5 kW. The QS273 V3 Motor is intended to be used with a vehicle for propulsion. The second item under consideration is identified as the QS268 90H Electric Motor, which is a 72 V BLDC electric motor having a double axle and a maximum power output of 50 kW. The QS273 V3 Motor is intended to be used with a vehicle for propulsion. |
| Reason: N/A |
| Ruling Date: June 2, 2025 |
N348878: The country of origin of motor control boards
| Origin: China |
| Item: There are three items under consideration, identified as Power Tool Controllers, each of which are described as encapsulated printed circuit board assemblies (PCBAs) that control the operation of an electric motor in personal power tools, where Model 1 is used in a sander/polisher and Models 2 and 3 are used in disc grinders. The production of the PCBAs occurs in China by surface mounting and through-hole insertion of multiple components, such as resistors, capacitors, diodes, transistors, triacs, and a potentiometer, onto a bare printed circuit board. Also in China, a heat sink is mounted to the PCBA, wires are soldered onto the board’s terminals, and the product is shipped to Japan. In Japan, the boards undergo testing, calibration of the potentiometer, mounting to a plastic case, and resin is filled into the PCBA/case. Also in Japan, the encapsulated PCBA is inspected, tested, and packed for export to the United States. |
| Reason: The production of the PCBAs in China by the surface mounting and through-hole insertion of multiple electronic components produces a PCBA of Chinese origin. However, in Japan, the calibration and addition of resin encapsulation does not substantially transform the PCBA into a new product in name, character, or use. As a result, the Power Tool Controllers are a product of China. |
| Ruling Date: June 2, 2025 |
N348937: The country of origin of a Segway off-road vehicle
| Origin: Thailand |
| Item: The item under consideration has been identified as the Segway off-road vehicle (Segway). Over 600 parts are shipped from China to Thailand and assembled into the finished vehicle. The main assembly line processes are highlighted below. The Segway will go through thirty-three (33) workstations. The entire assembly process takes thirty-four (34) workers approximately 15.55 hours per vehicle. |
| Reason: The raw materials imported into Thailand and used to manufacture Segway are not part of a knock down operation and the country of origin of the Segway is Thailand. |
| Ruling Date: June 2, 2025 |
N348979: The tariff classification of EPDM rubber automotive door glass run from South Korea
| HTS: 4016.93.1050, 9903.01.25, 2.5% + 10%, “other articles of vulcanized rubber other than hard rubber: other: gaskets, washers and other seals: of a kind used in the automotive goods of chapter 87: other.” |
| Item: An automotive door glass run composed of compact ethylene propylene diene monomer (EPDM) rubber. The part is shaped to fit the part of the automotive door frame that comes in contact with the glass window. The glass run serves as a guide when the window goes up and down. It maintains air and water tightness between the glass and frame while also absorbing external noise and door glass vibrations while driving or when the door is closed. |
| Reason: N/A |
| Ruling Date: June 2, 2025 |
N348998: The tariff classification of an electrical inverter from China
| HTS: 8504.40.9570, 9903.01.24, 9903.01.25, 9903.88.03, free + 10% + 20% + 25%, “Electric transformers, static converters and inductors…: Static converters: Other: Inverters.” |
| Item: The merchandise under consideration is identified as the TC Charger, PN CD-LW01, which is an electrical inverter that is used to charge the on-board batteries of an electric vehicle. The inverter incorporates intelligent monitoring for preventing damage during battery charging, is equipped with liquid cooling, and built-in heat sensing protection. The subject inverter has an output voltage of 144 VAC at 46 A. |
| Reason: N/A |
| Ruling Date: June 2, 2025 |
N349117: The tariff classification of packaging materials from China
| HTS: (Items 1, 4, 5 and 6) 4821.10.4000, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Paper and paperboard labels of all kinds, whether or not printed: Printed: Other.” (Items 2, 7, 8 and 9) 4823.90.8680, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Other paper, paperboard, cellulose wadding and webs of cellulose fibers, cut to size or shape; other articles of paper pulp, paper, paperboard, cellulose wadding or webs of cellulose fibers: Other: Other: Other: Other: Other: Other.” (Item 3) 3926.90.9989, 9903.01.24, 9903.01.25, 9903.88.15, 5.3% + 20% + 10% + 7.5%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” |
| Item: Item 1 is a die-cut label printed with product information about the plastic baby tub. The label is made from e-flute cardboard (a variety of thin corrugated cardboard), is printed (not lithographically) with five-color print, and is laminated with a matte plastic film. The label is printed on both sides with pictures, usage and safety information, and more. After importation, the label will be applied to the tub for retail sale. Items 2, 7, 8 and 9 are structural cardboard inserts. One is a strip of corrugated cardboard that is folded into a triangle and taped into shape. The second is a strip of corrugated cardboard that is folded into a rectangle and taped into shape. The third is a sheet of corrugated cardboard folded into a long, triangular shape and taped into shape. The fourth is a rectangular cube shape to be packaged with the baby tub to support the top of the packaging box. The inserts appear to function as spacers between the product and label or other items or supports within the product packing box. Item 3 is clear plastic zip ties. Item 4 is a self-adhesive, paper warning label printed with safety information. They are printed with two colors using inkjet printing. The labels are die-cut to rectangular shape. Item 5 is a self-adhesive, paper label printed with product information about the plastic baby tub. The labels are printed with five-color inkjet print. The labels will be die-cut to shape. Item 6 is a self-adhesive, paper label with legal information and a product bar code. The labels are printed by inkjet. The labels will be die-cut to rectangular shape. |
| Reason: N/A |
| Ruling Date: June 2, 2025 |
N349210: The tariff classification of concert paraphernalia from South Korea
| HTS: 4911.91.4040, 9903.01.31, 9903.01.32, free + 10%, “Other printed matter…: Pictures, designs and photographs: Printed not over 20 years at the time of importation: Other: Other: Other.” |
| Item: Two items are under consideration, both designed for fans of the South Korean boy band, TWS. The first is a “TWS 25 Tour Image Picket.” The picket is made of plastic and is paddle shaped, with a rounded top portion and a handle. The image of one band member is displayed on the face of each paddle, and his name is shown on the reverse. The images are printed on paper, which is then adhered to the plastic picket. The pickets would be appropriate to hold up at a concert. The second item is a small, flat, printed, plastic image of a band member on a stand, designed for display on a shelf or other flat surface. Each measure 11 cm x 13.5 cm. The color image of the band member is printed on paper, which is then adhered to the plastic backing. |
| Reason: N/A |
| Ruling Date: June 2, 2025 |
N349258: The tariff classification of EPDM rubber automotive door glass runs from South Korea
| HTS: 4016.93.1050, 9903.01.25, 2.5% + 10%, “other articles of vulcanized rubber other than hard rubber: other: gaskets, washers and other seals: of a kind used in the automotive goods of chapter 87: other.” |
| Item: Automotive door glass runs composed of compact ethylene propylene diene monomer (EPDM) rubber coextruded with a steel insert. The products are shaped to fit the side door glass frame of the automobile that comes in contact with the glass window. The glass runs serve as a guide when the window goes up and down. They maintain air and water tightness between the glass and frame while also absorbing external noise and door glass vibrations while driving or when the door is closed. |
| Reason: The automotive door glass runs are composite goods. The door runs form a seal between the door frame and the glass to prevent leakage as well as absorb external noise and door glass vibrations. It is the EPDM rubber component that facilitates these actions; therefore, the essential character of these door glass runs is imparted by the EPDM rubber component. |
| Ruling Date: June 2, 2025 |
N349545: The country of origin of a bow rake
| Origin: Vietnam |
| Item: The bow rake features 16-inch curved tines arranged in a straight alignment that is offset from a long handle by a pair of curved bows extending from both sides of the head of the rake. It is commonly used for spreading mulch, weed removal, tamping soil, breaking up compacted soil, and removing roots and rocks from cultivated beds. The manufacturing process begins in Vietnam, where Chinese-origin hot-rolled steel is laser-cut into a flat outline of the rake head. The tines of the rake head are divided and forged, and the curved bows are bend into shape. A handle connector is formed and welded into shape, and the rake head is then press-bent into its final curved shape. The fully formed rake head is then sent to China where it is polished, powder coated and assembled with a Chinese-origin wood or fiberglass handle. Finally, plastic grips are attached to the middle and end of the handle. |
| Reason: The cold-rolled steel is substantially transformed in Vietnam into a fully formed rake head. It is the rake head that imparts the essence of each finished bow rake. Based upon the finishing operations performed in China, the rake heads are not substantially changed to transform them into a new article with a different name, character, or use. Additionally, the rake head is not substantially transformed by the attachment of a wood or fiberglass handle. The country of origin of the finished bow rake is Vietnam. |
| Ruling Date: May 30, 2025 |
N334241: The tariff classification of a cotton woven upholstery fabric from Pakistan
| HTS: 5212.25.6030, 9903.01.25, free + 10%, “Other woven fabrics of cotton: Weighing more than 200 g/m2: Printed: Other: Other: Sheeting.” |
| Item: The fabric weighs 326.5 g/m2 and is composed of 78.8% cotton staple fibers and 21.2% linen staple fibers. The fabric is composed of single ply yarns in both the warp and filling direction. Additionally, the fabric contains 15 warp ends per one centimeter and 14 filling picks per one centimeter. The average yarn number for this fabric has been calculated to be 9 in the metric system. This fabric will be imported in 54-inch widths and will be used for upholstery. |
| Reason: N/A |
| Ruling Date: April 17, 2025 |