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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N349299: The tariff classification of a hydraulic hook crane attachment from the Czech Republic
| HTS: 8479.89.9599, 9903.01.25, 2.5% + 10%, “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” |
| Item: The Hiab Hydraulic Hook, model no. KM 920-5 with Rotator, is a hydraulically activated hook which attaches to Hiab’s medium-duty knuckle boom cranes. It is powered by the crane to which it is attached. The Hydraulic Hook has no ability to generate its own hydraulic power. This accessory crane attachment is designed to pick up pallet forks but can be used for various loads. As imported the Hydraulic Hook will be paired and used with a hydraulic Rotator which incorporates hydraulic cylinders and valves to safely and efficiently engage and disengage from crane loads. It weighs between 128-152 lbs and measures approximately 19 in. (H) x 12-18 in. (W), depending upon configuration, with a load capacity of 9,900 lbs. |
| Reason: N/A |
| Ruling Date: June 5, 2025 |
N349316: The tariff classification and country of origin of replacement reverse osmosis water filters
| HTS: 8421.21.0000, 9903.01.25, free + 10%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” |
| Origin: South Korea |
| Item: The filters are composed of a Chinese plastic shell, O-ring, sump and check valve, and a South Korean RO membrane. The filters are used with residential drinking water systems requiring an RO filter. In operation, water passes through the RO membrane filter and removes impurities such as residual chlorine, heavy metals, viruses, and scale, thus providing clean water.The filters are assembled in China using components manufactured in South Korea and China. The filter element is composed of a Chinese O-ring, upper cover, middle cover, bottom cover, sump, check valve, and a South Korean RO membrane filter. The RO membrane filter requires substantial processing to create and accounts for the largest cost of the overall filters. |
| Reason: The assembly process performed in China is not complex and does not constitute a substantial transformation. The process predominantly involves gluing, welding, and pressing various components into place. The combining of these parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the replacement RO water filters, it is the origin of the RO membrane filter, which provides the essential function of the filters. It is the RO membrane filter from South Korea which requires considerable technical expertise and customized equipment to produce. It is also the most expensive portion of the filters and is the item performing the filtering of the water. Accordingly, the country of origin of the replacement RO water filters will be South Korea, which is where the RO filter membrane is manufactured. |
| Ruling Date: June 5, 2025 |
N349413: The tariff classification of a compressor module from Canada
| HTS: 8414.80.2075, 9903.01.26, free, “Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not fitted with filters; parts thereof: Other, except parts: Other compressors: Other: Other, including reciprocating and rotary: Exceeding 746 kW.” |
| Item: The 461 Fuel Gas Import Compressor Module is installed at the Nanushuk Processing Facility in Alaska. The module consists of a fuel gas heater, a fuel gas booster compressor suction scrubber, fuel gas booster compressor suction and discharge bottles, a discharge coalescer, a discharge coalescer sump, a compressor frame lube oil supply tank, a compressor cylinder lube oil supply tank, a 881 kilowatt gas compressor, a waste oil tank, a seal pot vacuum pump, a seal pot, and a heating, ventilation and air conditioning (HVAC) system. The components, which are enclosed in a building and connected using pipes that incorporate valves and instrumentation controls, contribute to a principal function, which is to compress natural gas used to generate electricity. |
| Reason: N/A |
| Ruling Date: June 5, 2025 |
N349586: The tariff classification of a centrifuge from Japan
| HTS: 8421.19.0000, 9903.01.25, 1.3% + 10%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Centrifuges, including centrifugal dryers: Other.” |
| Item: The item under consideration is described as the TOMY MDX-310 centrifuge, which is a refrigerated laboratory device used to separate components in liquid samples by spinning them at high speeds. Its main purpose is to aid in tasks like isolating cells, blood components, DNA/RNA, and removing debris. It utilizes a rack-in-motor system, which allows for quick rotor swaps, and has a maximum capacity of three racks. The device accommodates samples from 1.5 mL to 2.0 mL tubes, 96-well plates, and larger 50 mL tubes. The induction motor can run from 300 to 15,000 revolutions per minute (RPM) in 100 rpm increments. The display and control panel allow for fine-tuning of the speed, time, and temperature settings. The device measures 341 mm wide by 491 mm deep by 823 mm high and weighs 62 kilograms. The MDX-310 is imported with an operator’s manual, rotor fixing knob, two caster holders, a drain plug, power cord, and hexagon wrench. |
| Reason: N/A |
| Ruling Date: June 5, 2025 |
N349606: The tariff classification and country of origin of a tool set
| HTS: 8466.10.0175, 9903.01.25, 3.9% + 10%, “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465…; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Other.” |
| Origin: Vietnam |
| Item: The item under consideration is described as a tool set comprising 109 items imported together inside of a plastic molded case, ready for retail sale. The contents of the set include: 1 - Pair of long nose pliers 1 - Pair of diagonal pliers 1 - Pair of groove joint pliers 10 - Sockets 22 - Hex keys 1 - Hammer 22 - Cable ties 1 - Ratchet Handle 1 - Magnetic bit driver 48 - Screwdriver bits 1 - Level.There are two manufacturing scenarios. In scenario one, all component items are Chinese origin except the ratchet handle and magnetic bit driver which are from Vietnam. In scenario two, all component items are Chinese origin except for the sockets, screwdriver bits, ratchet handle, and magnetic bit driver which are from Vietnam. |
| Reason: The ratchet handle and magnetic bit driver, functioning as tool holders, impart the essential character of the tool set because they are used with a large quantity of sockets (10) and screwdriver bits (48). Without the ratchet handle and magnetic bit driver, the utility of the sockets and screwdriver bits would be significantly hampered and thus the overall functionality of the tool set would be irreparably diminished.The ratchet handle and magnetic bit driver of Vietnamese origin impart the essential character of the 109-piece tool set and thus control the classification and country of origin of the entire set. Accordingly, the country of origin in both scenarios for Section 301 and other duty purposes is Vietnam. |
| Ruling Date: June 5, 2025 |
N348688: The country of origin of Dutasteride Capsules in dosage form
| Origin: Italy |
| Item: Dutasteride, imported in 0.5 mg capsules, is a synthetic steroid analogue. It is indicated for the treatment of symptomatic benign prostatic hyperplasia (BPH) in men with an enlarged prostate. The active pharmaceutical ingredient (API), Dutasteride, is manufactured in Italy and that the finished capsules in dosage form are made in China. In China, Dutasteride will be mixed with various inactive ingredients to produce the final Dutasteride capsules in dosage form. |
| Reason: The mixing of the active ingredient Dutasteride (made in Italy) with the inactive ingredients into the final dosage Dutasteride capsules in China does not result in a substantial transformation and the country of origin will be Italy. |
| Ruling Date: June 4, 2025 |
N348723: The country of origin of Potassium Chloride Extended-Release Capsules, USP
| Origin: U.S. |
| Item: Potassium Chloride, imported in 8 mEq and 10 mEq extended-release capsules, is a medicinal preparation containing Potassium Chloride, as the active ingredient. It is indicated for the treatment and prophylaxis of hypokalemia with or without metabolic alkalosis. The active pharmaceutical ingredient (API), Potassium Chloride is manufactured in the United States and that the finished capsules in dosage form are made in India. In India, the Potassium Chloride will be mixed with various inactive ingredients to produce the final capsules in dosage form. |
| Reason: The mixing of the active ingredient Potassium Chloride (made in the United States) with the inactive ingredients into the final dosage capsules in India does not result in a substantial transformation and the country of origin will be the United States. |
| Ruling Date: June 4, 2025 |
N348762: The tariff classification of a food trailer from China
| HTS: 8419.81.9040, 9903.01.24, 9903.01.25, 9903.88.15, free + 20% + 10% + 7.5%, “Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving a change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Other machinery, plant or equipment: For making hot drinks or for cooking or heating food: Other: Of a type used in restaurants, hotels or similar locations.” |
| Item: The merchandise under consideration is a fully equipped food trailer and is described as a double-axle enclosed trailer that will be used as a mobile restaurant. It measures approximately five meters in length, two meters in width, two and three-tenths meters in height, and weighs 1,650 kilograms. The trailer will have a built-in concession window with a foldable service counter. Permanently installed inside the unit are commercial cooking appliances, including a single deck gas oven, a flat-top gas grill, a dual-burner gas stock pot stove, a six-pan steaming and warming unit, a single-tank gas fryer, dual-tank gas fryer, and an electric salamander broiler. The appliances are integrated into stainless-steel cabinetry and alongside a range hood, refrigerator, freezer, and bolted down work benches. |
| Reason: The food trailer is not designed for the transport of goods or persons, but rather to cook and serve food. Furthermore, it is equipped with distinct machinery that gives it its essential character. The essential character of the trailer is imparted by the commercial cooking equipment permanently mounted inside the trailer, which include both stoves and other cooking appliances classified in heading 8419, HTSUS. |
| Ruling Date: June 4, 2025 |
N348771: The tariff classification of Alanine, N, N-bis(carboxymethyl)-, trisodium salt (MGDA-3Na) (CAS No. 164462-16-2) from China
| HTS: 2922.49.4950, 9903.01.24; 9903.01.32; 9903.88.03, 4.2% + 20% + 10% + 25%, “Oxygen-function amino-compounds: Amino-acids, other than those containing more than one kind of oxygen function, and their esters; salts thereof: Other: Other: Amino acids: Other amino acids: Other.” |
| Item: The subject product, Alanine, N, N-bis(carboxymethyl)-, trisodium salt, is also known as MGDA-3Na. It will be used in detergents and will be imported in 750-kilogram super bags. |
| Reason: N/A |
| Ruling Date: June 4, 2025 |
N348796: The tariff classification of a set of earrings and a bracelet from China
| HTS: 9811.00.60, free, “Any sample (except samples covered by heading 9811.00.20 or 9811.00.40), valued not over $1 each, or marked, torn, perforated or otherwise treated so that it is unsuitable for sale or for use otherwise than as a sample, to be used in the United States only for soliciting orders for products of foreign countries.” |
| Item: Sample A is a pair of earrings constructed of zinc alloy. Each earring is laser-marked with the word “SAMPLE” inside the earrings. The declared value is $1.19. Sample B is a stretch bracelet constructed of zinc alloy. The bracelet is laser-marked with the word “SAMPLE” on the interior. The declared value is $1.26. |
| Reason: As the articles are permanently laser-etched with the word, “SAMPLE,” rendering them unsuitable for commercial sale and clearly indicating their restricted use as samples, they are eligible for classification under subheading, 9811.00.60. |
| Ruling Date: June 4, 2025 |