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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N348995: The tariff classification, country of origin, and marking of shoe accessory kits from China and Italy; 19 CFR 102.21(c)(2)
| HTS: 6307.90.9891, 9903.01.24, 9903.01.25, 9903.88.15, 7% + 20% + 10% + 7.5%, “Other made up articles, including dress patterns Other: Other: Other: Other: Other.” |
| Origin: Italy and China |
| Marking: Insufficient |
| Item: Assortments of shoe ornaments and shoelaces designed to provide a unique look to the wearer’s shoe. The sets include 100% leather, plastic or polyester shoelaces and ornaments and accessories that may include decorative coins, beads, metal key accessories with a ring, imitation jewelry, textile flowers, lettered pieces and ribbons. The items come packaged in a clear and resealable plastic bag. |
| Reason: The Cowboy, Hippy, and Scout accessories sets comprise braided fabric shoelaces formed in a single country, that is Italy. Therefore, the country of origin of the braided fabric shoelaces are conferred in Italy. The Glam accessories set comprises a 100% polyester woven ribbon shoelace formed in a single country, that is China. Therefore, the country of origin of the woven ribbon shoelace is conferred in China. The originating textile components packaged in the Cowboy, Glam, Hippy, and Scout accessories sets are not substantially transformed as a result of being packaged with the non-originating textile components, and the individual components and the origin of all items packaged with the bundle must be identified. Consequently, each article must be individually marked with their country of origin, provided such marking is visible through the retail packaging of the bags, or the packaging must identify the origin of each of these items. |
| Ruling Date: June 6, 2025 |
N349014: The country of origin of a control arm and ball joint assembly
| Origin: Thailand |
| Item: The article under consideration is a control arm and ball joint assembly, which is a component of a suspension system in passenger vehicles. It is made of steel with plastic and rubber components. The ball joint is integrated into the L-shaped control arm. The manufacturing process takes place in Thailand where the steel bars imported from China are forged into the raw ball stud and housing (socket) blanks. The raw ball stud is further processed using a high-precision CNC machine to shape the ball head and stud (cylindrical shank) of the ball stud. Then a pin hole is drilled at the bottom of the ball stud. Finally, a thread rolling (cold forming) operation is performed to enhance the strength, durability, and precision of the finished ball stud. Next, the housing blanks are further shaped by the high-precision CNC machine via precise turning of the housing blanks. Once the housing is complete, it is joined together with the ball stud to create the finished ball joint assembly. The control arm is also manufactured in Thailand using the raw steel imported from China. The raw steel is stamped in the shape of the control arm and further processed by punching and flanging of the control arm. After that, the ball joint assembly is press fitted into the control arm to create the finished control arm and ball joint assembly. |
| Reason: The raw steel and steel bars imported from China undergo extensive machining, stamping, flanging, and other processes and become distinct components of the control arm and ball joint. These processes physically change the raw materials into an article with a new name, character, and use. As a result, the control arm and ball joint assembly are substantially transformed in Thailand. |
| Ruling Date: June 6, 2025 |
N349094: The tariff classification, country of origin determination, and HOPE eligibility for a pregnancy support belt; 19 CFR 102.21(c)(2)
| HTS: 6307.90.9891, 9903.01.24, 9903.01.25, 9903.88.15, 7% + 20% + 10% + 7.5%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Origin: China |
| HOPE Eligibility: No |
| Item: The “Motif Medical - Pregnancy Band” is a textile support belt designed to be worn around the abdomen and provide support, comfort, and stability for a woman during pregnancy. The support belt consists of five panels which are sewn together around the edges with an 88% polyester and 12% spandex knit binding fabric. The two end panels are composed of an outer layer of 100% nylon knitted velvet fabric, a middle layer of 100% polyester knitted fabric, and an inner layer of 88% polyester and 12% spandex knitted fabric. Each of the panels sewn to the end panel is composed of an outer layer of 100% polyester knitted fabric and an inner layer of 88% polyester and 12% spandex knitted fabric. The middle panel is composed of a double layer of 95% polyester and 5% spandex knitted mesh fabric. |
| Reason: The country of origin of a good classifiable under 6307.90 is the country, territory, or insular possession in which the fabric comprising the good was formed by a fabric-making process. The pregnancy support belt comprises multiple panels of fabric sewn together, and each of these fabrics is formed by a fabric-making process in a single country, that is China. Therefore, pursuant to 19 CFR 102.21(c)(2), the country of origin of the pregnancy support belt is China. Because the pregnancy support belt is a made up textile article classified under subheading 6307.90.9891, it is excluded by Chapter 98, Subchapter XX, U.S. Note 6(r)(ii). Therefore, the “Motif Medical – Pregnancy Band” is not eligible for preferential duty treatment under HOPE. |
| Ruling Date: June 6, 2025 |
N349097: Classification and country of origin determination for automobile floor mats; 19 CFR 102.21(c)(2); tariff shift
| HTS: 5704.90.0190, 9903.01.25, free + 10%, “Carpets and other textile floor coverings, of felt, not tufted or flocked, whether or not made up: Other: Other.” |
| Origin: Malaysia |
| Item: An automobile floor mat set which includes two front mats and two rear mats. The mats are composed of 100% polyester needle-loomed felt fabric backed with polyvinyl chloride (PVC) to create a non-skid surface. The four mats feature 100% polypropylene woven binding along the edges and 2-inch-wide PVC faux leather accents at the sides. The driver’s mat also includes a PVC faux leather heel cushion. The manufacturing operations for the floor mats are as follows: In China, polyester fibers are extruded, cut and dyed. Dyed polyester staple fibers are carded to form a web. Polyester felt fabric is formed by entangling the fibers using barbed needles. Faux leather is formed. Polypropylene binding is woven and dyed. Polyester needle-loomed felt fabric, polyvinyl chloride (faux leather) and polypropylene binding are exported to Malaysia.In Malaysia, PVC granules are formed. Needle-loomed felt polyester fabric is laminated with PVC. Laminated polyester needle-loomed felt fabric is cut to shape of mat. Faux leather (PVC) is cut to shape. Faux leather (PVC) heel pad is pressed on top of mat. Faux leather (PVC) side accents are pressed and sewn on the mat. Woven polypropylene binding is sewn around the edges of each mat. Completed mat set is packaged and exported to the United States. |
| Reason: The needle-loomed felt polyester fabric is lightweight and measures approximately 1/8 inch in thickness; it lacks the stiffness, thickness, and strength of a textile floor covering on its own. As all of the components of the automobile mats make the tariff shift in a single country, that is, Malaysia, as per the terms of the tariff shift requirement, country of origin is conferred in Malaysia. |
| Ruling Date: June 6, 2025 |
N349137: Country of origin determination for jacquard duvet cover and sham set; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred
| Origin: China and Thailand |
| Item: The item, “Frosted Scroll Full/Queen Duvet Cover and 2pc Sham Set,” consists of a jacquard woven duvet cover and two pillow shams. The front panel of the duvet cover is composed of yarn dyed, 69% polyester, 26% rayon and 5% metallic jacquard fabric woven with a leaf design. The back panel is of dyed 100% cotton sateen woven fabric. The fabrics are neither napped nor printed. The duvet cover features a welted edge, self-flange, and an opening with a zippered closure along the bottom edge. The manufacturing operations for the jacquard duvet cover and two pillow sham set are as follows: In China, polyester/rayon jacquard woven fabric is formed. Polyester/rayon jacquard woven fabric is finished by shrinking and permanent stiffening. The finished polyester/rayon jacquard woven fabric is shipped in rolls to Thailand. In Thailand, cotton sateen woven fabric is formed. Cotton sateen woven fabric is dyed and finished by shrinking and permanent stiffening. Thread and zipper are formed. Fabrics are cut and assembled by sewing into a duvet cover and pillow shams. The finished set is packaged and shipped to the United States. |
| Reason: Since the fabric forming the pillow shams is woven in a single country, that is, China, the country of origin of the shams is conveyed by the fabric-making process in China. Pursuant to 19 CFR 102.21(e)(2)(ii), the origin of the pillow shams is China. In the case of the subject duvet cover, the country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Thailand. |
| Ruling Date: June 6, 2025 |
N349138: Country of origin determination for jacquard duvet cover and sham set; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred
| Origin: China and Thailand |
| Item: The sample, “Quartz Full Queen Duvet Cover and 2 pc Sham Set,” consists of a jacquard duvet cover and two pillow shams. The manufacturing operations for the jacquard duvet cover and two pillow sham set are as follows: In China, polyester/rayon jacquard woven fabric is formed. Polyester/rayon jacquard woven fabric is finished by shrinking and permanent stiffening. The finished polyester/rayon jacquard woven fabric is shipped on rolls to Thailand.In Thailand, cotton sateen woven fabric is formed. Cotton sateen woven fabric is dyed and finished by shrinking and permanent stiffening. Thread and zipper are formed. Fabrics are cut and assembled by sewing into a duvet cover and pillow shams. The finished set is packaged and shipped to the United States. |
| Reason: Since the shams are constructed from fabric woven in a single country, that is, China, the country of origin of the shams is conveyed in China where the fabric-making process occurs. In the case of the subject duvet cover, the country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Thailand. |
| Ruling Date: June 6, 2025 |
N349197: Classification and country of origin determination for duvet cover and sham set; 19 CFR 102.21(c)(2); tariff shift
| Origin: China |
| Item: The subject merchandise consists of a duvet cover and 2-piece sham set. The manufacturing operations for the duvet cover and shams are as follows: In China, dobby weave cotton face fabric is woven and dyed. Plain woven cotton back fabric is woven and dyed. Both face and back fabrics are shipped in rolls to Pakistan. In Pakistan, fabrics are cut and assembled by sewing into finished duvet cover, shams and bag. Finished duvet cover and shams are inspected, folded, packaged and shipped to the United States. |
| Reason: As the fabrics comprising the duvet cover and pillow shams are formed in a single country, that is, China, the country of origin is conferred in China. |
| Ruling Date: June 6, 2025 |
N349253: Classification and country of origin determination for quilted blanket; 19 CFR 102.13; De Minimis; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred
| HTS: 6301.40.0020, 9903.01.25, 8.5% + 10%, “blankets (other than electric blankets) and traveling rugs, of synthetic fibers, other.” |
| Origin: Pakistan |
| Item: The subject merchandise, “Cooling Touch Down Alternative Throw,” is a quilted blanket comprised of three layers: two fabrics and fiberfill. The face side is composed of 77% nylon and 23% polyethylene, dyed, knitted fabric and the reverse side is composed of 100% polyester, dyed, woven fabric. Polyester fiberfill is stuffed between the two fabrics. The three layers are quilted together in a wavy block pattern. The blanket measures 50 x 60 inches and is finished along the edges with 100% polyester brushed knit binding. It will be packaged and imported for retail sale with a single ribbon with hook and loop tabs. The item is intended for indoor use to provide warmth to an individual. The manufacturing operations for the quilted blanket are as follows: In China, Nylon/polyethylene face fabric is knitted and dyed. Knitted nylon/polyethylene face fabric is shipped in rolls to Pakistan.In Pakistan, polyester backing fabric is woven and dyed. Polyester fiberfill material is formed. Polyester brushed knit binding is formed. Fabrics are cut, assembled by sewing, filled and quilted. Finished quilted blankets are exported to the United States. |
| Reason: The country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Pakistan. |
| Ruling Date: June 6, 2025 |
N349307: Country of origin determination for a comforter set; 19 CFR 102.21(c)(5); last country where an important assembly or manufacturing process occurred
| Origin: Pakistan |
| Item: The subject merchandise consists of a comforter and 2-piece pillow sham set. The manufacturing operations for the comforter and shams are as follows: In China, Polyester face fabric is woven, heat treated and printed. Polyester face fabric exported to Pakistan in rolls.In Pakistan, Polyester back fabric is woven and printed. Filling for the comforter is formed. Fabric is cut. Comforter shell and shams are assembled and sewn. Fiberfill is inserted into the comforter shell. Comforter is tacked and sewn closed. Comforter sets are exported to the United States. |
| Reason: The country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Pakistan. |
| Ruling Date: June 6, 2025 |
N349313: The country of origin of the Electric Vehicle Battery Charger
| Origin: South Korea |
| Item: The merchandise under consideration is identified as the Electric Vehicle Battery Charger (Charger), which is described as an enclosure containing electrical distribution apparatus, a front facing touchscreen control interface, dual charging controllers, an AC/DC converter, a DC/DC converter, and various control and payment/communication circuitry. The 32” LCD user touchscreen incorporates a payment system and can be configured for advertisement and/or video as well as system status. On the top of the unit is a banner LED display that is used to notify users of availability and status. Extending from each side of the enclosure are two electrical cables that are intended to attach to an electric vehicle for periodic charging. The inverter, which you identify as the Power Block, is manufactured in China. In Korea, eight printed circuit board assemblies (PCBAs), identified as the Main Control Board, the IMD Board, the Power ADC Board, the LED Sub Board, and the DP Reset Board, are manufactured by soldering individual components, such as resistors, capacitors, integrated circuits, transformers, etc. onto bare printed circuit boards through a surface mount and/or through-hole insertion process. Also in Korea, the Korean origin Industrial PC is integrated, the human machine interface, numerous circuit breakers, electrical connection apparatus, and cables, which are said to be manufactured in Korea, are assembled into the enclosure. The charger is tested and packaged for export to the United States. |
| Reason: The assembly of the PCBAs by soldering the individual components of various origins onto bare printed circuit boards in Korea results in a substantial transformation of those components to produce five PCBAs of Korean origin. While the Power Module, which is produced in China, is an important component of the Charger, in our view, the Korean origin electrical conversion, control, and distribution, as well as the assembly operation occurring in Korea, establish the bulk of the functionality of the Charger. As a result, the Electric Vehicle Battery Charger (Charger) is considered a product of Korea at the time of importation into the United States. |
| Ruling Date: June 6, 2025 |