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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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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.

N349460: The tariff classification of affirmation cards from China

HTS: 4911.99.6000, 9903.01.22, 9903.01.31, 9903.88.15, free + 20% + 10% + 7.5%, “Other printed matter: Other: Other: Other: Printed on paper in whole or in part by a lithographic process.”
Item: The item under consideration is a boxed set of affirmation cards titled “Sinister Affirmations, Mantras for Formidable Women.” The 52 cards are lithographically printed with an affirmation on the face and a design on the back. An example of an affirmation is, “Remember, mild inconvenience is temporary, spite is forever.” The cards measure approximately 4" x 6" and come packaged with a small stand for displaying one card at a time.
Reason: N/A
Ruling Date: June 3, 2025

N349533: The country of origin of napkins

Origin: Vietnam
Item: The paper products under consideration are "dispenser napkins." They come in either single or double ply with 1/4, 1/6 or 1/8 fold. The bulk rolls of napkin stock are manufactured in Vietnam. The paper is White/Kraft 100% wood pulp virgin paper; layer:1-2; 13.5-22g/sm. These parent rolls of tissue paper, which measure in multiple widths from 380mm up to 1495mm and have a maximum roll diameter of 1595mm, are then sent to China, where the paper is embossed, cut and folded to length and width. No shaping is done. The napkins are then subjected to quality control and packaged.
Reason: In China, the napkin stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by printing, cutting, folding and packaging. The country of origin of the finished napkins is Vietnam.
Ruling Date: June 3, 2025

N349534: The country of origin of paper towel sheets and rolls

Origin: Vietnam
Item: The paper products under consideration are "hand towel sheet" and "hand towel roll." They come in either single or double ply with 1/3-fold, 1/6-fold or in rolls. The bulk rolls of paper towel stock are manufactured in Vietnam. The paper is white/kraft 100% wood pulp virgin paper; layer:1-2; 16-45 g/sm. These parent rolls of tissue paper, which measure in multiple widths from 660mm up to 2850mm and have a maximum roll diameter of 2850mm, are then sent to China, where the paper is unwound, embossed, rewound, cut to length and width, and folded or rewound. The paper towel is then subjected to quality control and packaged.
Reason: In China, the paper towel stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by unwinding, embossing, cutting, folding or rewinding, and packaging. The country of origin of the finished hand towels is Vietnam.
Ruling Date: June 3, 2025

N349536: The country of origin of toilet paper

Origin: Vietnam
Item: The paper products under consideration are "toilet tissue" and "jumbo roll tissue." They come in rolls in either single, double or triple ply. The bulk rolls of toilet tissue stock are manufactured in Vietnam. The paper is White/Kraft 100% wood pulp virgin paper; layer:1-3; 12.5-21 g/sm. These parent rolls of tissue paper, which measure in multiple widths from 2760mm up to 2830mm and have a maximum roll diameter of 2830mm, are then sent to China, where the paper is unwound, embossed, rewound, and cut to size. The toilet tissue is then subjected to quality control and packaged.
Reason: In China, the toilet tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by unwinding, embossing, winding, cutting and packaging. The country of origin of the finished toilet tissue is Vietnam.
Ruling Date: June 3, 2025

N348588: The tariff classification of Indacaterol Base (CAS No. 312753-06-3) in bulk powder form, from Spain

HTS: 2933.79.0800, 9903.01.32, free + 10%, “Heterocyclic compounds with nitrogen hetero-atom(s) only: Lactams: Other lactams: Aromatic or modified aromatic: Other: Products described in additional U.S. note 3 to section VI.”
Item: Indacaterol is a long-acting bronchodilator. It is indicated for the long-term maintenance treatment of airflow obstruction in patients with chronic obstructive pulmonary disease (COPD), including chronic bronchitis and emphysema.
Reason: N/A
Ruling Date: June 2, 2025

N348638: The tariff classification of two pumpkin carving sets from Indonesia

HTS: (Pumpkin Carving Kit 5pcs) 8211.10.0000 / 8211.92.9030, 9903.01.25, .8¢/each + 4.6% + 10%, “[k]nives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof: [s]ets of assorted articles.” (Pumpkin Carving Kit 4pcs) 8211.92.2000, 9903.01.25, .8¢/each + 4.6% + 10%, “[k]nives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof: [o]ther: [o]ther knives having fixed blades: [w]ith rubber or plastic handles: [k]itchen and butcher knives.”
Item: There are two products under consideration. The first set is described as the “Pumpkin Carving Kit 5pcs." It consists of three carving knives, listed as a detailer, a miter carver, and a small carver. They all feature blades made of iron and handles of acrylonitrile butadiene styrene (ABS) plastic. Also included in this kit is a poker tool and scoop both made wholly of ABS plastic. The second set is described as the “Pumpkin Carving Kit 4pcs." It consists of two carving knives, listed as a carver and a detailer. They feature blades made of iron and handles of ABS plastic. Also included in this kit is a tracer tool with a working surface of iron and a handle of ABS plastic and scoop made wholly of ABS plastic.
Reason: The five-piece set consists of three knives and two other articles. As such, it meets the note for subheading 8211.10, and it would be appropriately classified under subheading 8211.10. In contrast, the four-piece set has two knives and two other articles, so the knives would not predominate over the other articles. Therefore, it will be classified in accordance with General Rule of Interpretation 3(b) by the knives as they would impart the essential character to the set.
Ruling Date: June 2, 2025

N348740: The tariff classification of a plastic storage bin from Malaysia

HTS: 3926.90.9989, 9903.01.25, 5.3% + 10%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.”
Item: The product under consideration is described as a warehouse holding container. It is made of polypropylene plastic and measures 560 millimeters (length) by 345 millimeters (width) by 218 millimeters (height). This blue rectangular-shaped bin features side grips and lacks a lid.
Reason: N/A
Ruling Date: June 2, 2025

N348786: The tariff classification of multilayer wood flooring from Indonesia

HTS: (panels with a 4.11mm- or 4.22mm-thick face ply of oak) 4418.75.7000, 9903.01.25, 5% + 10%, “Builders' joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and shakes: Assembled flooring panels: Other, multilayer: Other.” (panels with a 3.9mm-thick face ply of oak and a back ply of Jabon or Sengon) 4412.51.3105, 9903.01.25, 8% + 10%, “Plywood, veneered panels and similar laminated wood: Blockboard, laminboard and battenboard: With at least one outer ply of tropical wood: Plywood: Not surface covered, or surface covered with a clear or transparent material which does not obscure the grain, texture or markings of the face ply: Other: Wood flooring.”
Item: The product under consideration is a multilayer wood flooring panel. The flooring panel is constructed of 3 wood plies. The face ply, measuring 4.11mm in thickness for one sample and 4.21mm for another, consists of a continuous sheet of white oak (Quercus alba., a non-coniferous wood) wood veneer. The center ply, measuring approximately 9.8mm to 10mm in thickness, consists of blocks of rubberwood (Hevea spp., a tropical, non-coniferous wood) wood. The back ply, measuring approximately 1.35 to 1.75mm in thickness, consists of Jabon (Anthocephalus cadamba, also known as Kadam) or Sengon (Paraserianthes falcataria, also known as Batai).veneer. Both Jabon and Sengon are tropical, non-coniferous woods. The grain of the center ply runs at a 90-degree angle to that of the face and back plies. The surface of the face ply is coated with a clear urethane that does not obscure the face ply. The panel is tongued and grooved on its edges and ends.
Reason: N/A
Ruling Date: June 2, 2025

N348828: The tariff classification of a programmable controller and limit switch from Mexico

HTS: (Multi-Function Control Panel) 8537.10.9160, 9903.01.04, 2.7%, “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity, …: For a voltage not exceeding 1,000 V: Other: Other: Other: Programmable controllers.” (Limit Switch Assembly) 8536.50.9055, 9903.01.04, 2.7%, “Electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits (for example, switches…), for a voltage not exceeding 1,000 V: Other switches: Other: Other: Limit.”
Item: The first item under consideration is identified as the Multi-Function Control Panel (Controller), which is a plastic enclosure housing multiple printed circuit board assemblies, four front-facing electrical switches, and a front-facing plastic switch operator cover. In use, the Controller is mounted to the wall to electrically control the operation of a garage door. The Controller is programmable, in that it can communicate and synchronize with keyless openers, control and/or disable the keyless openers, and adjust the timing of lights. The second item under consideration is identified as the Limit Switch Assembly, which is a plastic housing with two adjustable drive contacts and a main drive gear contact. In use, the Limit Switch Assembly is mounted to a garage door opener to facilitate the upper and lower limits of the door position to prevent injury or damage.
Reason: N/A
Ruling Date: June 2, 2025

N348861: The tariff classification of a plastic syringe from China

HTS: 3926.90.2100, 9903.01.24, 9903.01.25, 9903.88.15, 4.2% + 20% + 10% + 7.5%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [i]ce bags; douche bags, enema bags, hot water bottles, and fittings therefor; invalid and similar nursing cushions; dress shields; pessaries; prophylactics; bulbs for syringes; syringes (other than hypodermic syringes) and fittings therefor, not in part of glass or metal.”
Item: The merchandise under consideration is a graduated 30-milliliter Luer Lock disposable plastic syringe. It is intended for use with a breathing sampling kit. The barrel is 117 millimeters in length with an inner and outer diameter of approximately 21.5 and 24 millimeters, respectively. It will be imported in bulk and will be non-sterile.
Reason: N/A
Ruling Date: June 2, 2025