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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N348903: The tariff classification of a shrink art kit from China
| HTS: 9503.00.0073, 9903.01.24, 9903.01.63, free + 20% + 10%, “Tricycles, scooters, pedal cars, and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended for use by persons: 3 to 12 years of age.” |
| Item: The product is described as a do-it-yourself shrink art kit which consists of 48 pre-cut shrinking plastic charms, 15 colored ball chains, 2 colored cords, 8 paint markers and 1 instruction sheet. Users will color each of the shrinking plastic charms using the markers on the textured side of the charm. The charms will then be placed into an oven, or toaster oven for 1 to 3 minutes, which will result in the charms shrinking up to 50% of their original size. Once the charms have completely cooled down the user can use the ball chain provided to create keychains. Cords can be cut down to desired length to hang the charms onto backpacks, zipper pulls and more. The Shrink-Its! kit is principally designed for the amusement of children 6 years of age and older. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N348907: The tariff classification of AFO Symmetry Straps from China
| HTS: 9021.10.00900, 9903.01.24; 9903.01.25, free + 20% + 10%, “[o]rthopedic appliances …: [o]rthopedic or fracture appliances, and parts and accessories thereof: [o]ther.” |
| Item: The Thrive Othopdedics Ankle Foot Orthosis (AFO) Symmetry Strap (T-strap) has a T-shape with straps that wrap around the ankle and attaches to the lateral strut of the AFO brace and its distal end that attaches to the bottom of the AFO's footplate. It contains a D-ring and a Thrive logo. The T-strap is specifically designed to provide varus or valgus correction by securing the foot in a neutral position within the AFO brace. It is critical for managing medial-lateral instability. The strap comes in one size: Universal, Left (SKU number TS-L), and Right (SKU number TS-R). The Symmetry Strap is only intended for use in conjunction with Thrive Orthopedics F-Series AFOs. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N349024: The tariff classification of orthopedic appliances for foals from Germany
| HTS: 9021.10.0090, 9903.01.25, free + 10%, “[o]rthopedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances …: [o]rthopedic or fracture appliances, and parts and accessories thereof: [o]ther.” |
| Item: Item 1 is described as Dalric D1, D2, and D3 Heel Extensions. They are therapeutic foal shoes with heel extensions used for foals to treat weak flexor tendons (flaccidity). They feature a flat plate in the bottom with a hole and a curve in the back to fit the curve of the hoof. Item 2 is described as Dalric Ext1 and Dalric Ext2 (Dalric Lateral / Medial Extensions Shoes). They are said to be therapeutic foal shoes with adjustable medial/lateral extensions to treat toe-in ankles, bowed and offset knees, bowed hocks, knock knees and valgus hocks. Item 3 is described as Dallmer B0, Dallmer Dalric B1 and Dallmer Dalric B2. They are said to be therapeutic foal shoes with attachable heel wedges to treat clubfoot or contracted tendons. Item 4 is described as Dalric C3 plastic cuff with aluminum medial/lateral extension plate, which is said to be a therapeutic foal shoe. The C3 Plastic Cuff is fitted to the foal’s foot and then attached to the aluminum extension plate either on the lateral or medial side to treat toe-in ankles, bowed and offset knees, bowed hocks, knock knees, and valgus hocks. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N349066: The tariff classification of parts of AFO braces from China
| HTS: 9021.10.0090, 9903.01.24; 9903.01.25, free + 20% + 10%, “[o]rthopedic appliances …: [o]rthopedic or fracture appliances, and parts and accessories thereof: [o]ther.” |
| Item: The pads have special shapes and configurations for replacing AFO padding. The straps are hook and loop straps featuring buckles, finger loops, and adaptive closures to assist patients with limited dexterity, enabling independent donning and doffing of their AFOs. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N349224: The tariff classification of an industrial vacuum system from Mexico
| HTS: 8479.89.9599, 9903.01.27, 2.5%, “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 AutoVac Industrial Vacuum System is designed for outdoor use at commercial car wash facilities. This electrically powered, interconnected system is comprised of motor-powered turbine blowers for generating vacuum, centrifugal action filter separator tanks each comprised of a tank-shaped steel frame housing and filter bag, cyclonic first stage mini particle separators, and several side-by-side vacuum stations, each with its own vacuum hose, which allows multiple users to vacuum their own vehicles simultaneously. The system also features a Vacuum IQ system, which is an electronic motor control system that manages the vacuum motors, and an electrical disconnect box. Each vacuum station is comprised of vertical steel tubular posts (flanged stanchions) through which vacuum pipes will run. Each stanchion post will support one first stage mini particle separator and one LED-lighted overhead arched steel tube that provides branching for the vacuum system suction hoses as well as a support base for shade canopies of various materials. The complete system also includes couplings, various elbows and pipes, check valves, air guns, coil air hoses, suction hoses, vacuum nozzles and similar vacuum tools, and various dedicated connectors, brackets, and hardware for assembling the system. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N349229: The tariff classification of Cat Litter from China
| HTS: 2302.50.0000, 9903.01.24; 9903.01.25, 1.4% + 20% + 10%, “Bran, sharps (middlings) and other residues, whether or not in the form of pellets, derived from the sifting, milling or other working of cereals or of leguminous plants: Of leguminous plants.” |
| Item: The product is pelletized and primarily composed of a soybean byproduct known as okara, a material obtained from solids that remain following soymilk production. Additional ingredients include corn starch and guar gum as binding agents, along with corn flour and activated charcoal to aid in odor and moisture control. Each retail unit is packaged in a vacuum-sealed polyethylene bag designed to protect the pellets and maintain freshness. Each bag weighs 6.17 pounds (2.8 kilograms). Bags are packed together in a corrugated cardboard master carton for shipping and for sale as a two-pack unit. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N349285: The country of origin of desktop personal computers
| Origin: Vietnam and Thailand |
| Item: The merchandise under consideration is described as four models of automatic data processing (ADP) machines or personal computers (PCs). The first PC is identified as the Chromebox Desktop Computer (Chromebox PC), which is described as a 16 cm by 12 cm by 3 cm enclosure containing the motherboard printed circuit board assembly (PCBA) motherboard, system memory, solid state storage (SSD), and a heat sink. The second PC under consideration is identified as the Mini PC Desktop Computer (Mini PC), which is described as a 16 cm by 12 cm by 3 cm enclosure containing the motherboard PCBA, system memory, SSD, and a heat sink. The third PC under consideration is identified as the Tower Desktop Computer (Tower PC), which is described as a 10 cm by 33 cm by 30 cm enclosure containing the motherboard PCBA, system memory, SSD, optical drive, graphics processing unit, and a 300W power supply. The fourth PC under consideration is identified as the All-in-One Desktop Computer (AIO PC), which is described as a 54 cm by 16 cm by 42 cm enclosure containing the motherboard PCBA, 24” IPS touchscreen enabled LED display, system memory, SSD, optical drive, graphics processing unit, web cam, and speakers. |
| Reason: Regarding the origin of the subject PCs, the assembly of the PCBA in Vietnam/Thailand, as noted above, by soldering individual components of various origins onto a bare printed circuit board results in a substantial transformation of those components to produce a motherboards of Vietnam/Thailand origin. Furthermore, the motherboard PCBA establishes the function of the PC because it is the article within the assembly that houses and controls the interconnection of the processor CPU, memory, and contains the BIOS that enables the ADP machine to function. Lastly, the assembly work conducted in China, which entails basic assembly by inserting, plugging, fastening, etc. does not substantially transform the motherboard PCBA into a new and different article. As a result of the forgoing, the Chromebox Desktop Computer and the Tower Desktop Computer are considered products of Thailand for origin purposes at time of importation into the United States. Likewise, the Mini PC Desktop Computer and the All-in-One Desktop Computer (AIO PC) are considered products of Vietnam for origin purposes at the time of importation into the United States. |
| Ruling Date: June 9, 2025 |
N349400: The tariff classification of a plastic anti-fatigue mat from China
| HTS: 3924.90.1050, 9903.01.24; 9903.01.25, 3.3% + 20% + 10%, “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Other: Curtains and drapes, including panels and valances; napkins, table covers, mats, scarves, runners, doilies, centerpieces, antimacassars and furniture slipcovers; and like furnishings. Other.” |
| Item: The merchandise under consideration is as an anti-fatigue polyvinyl chloride (PVC) kitchen mat. It is made of 100% PVC. The article has a digital and floral printing on the top. The pad comes in two sizes: a small one measuring approximately 20 inches long by 34 inches wide by 0.47 inches in thickness and a large one measuring approximately 20 inches long by 54 inches wide by 0.47 inches in thickness. This article is designed as a pad for standing while cooking and washing dishes in the kitchen. It relieves the stress and fatigue on the feet, legs, and back that can result from standing in one place for an extended period. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N349470: The tariff classification of a fire pit from China
| HTS: 7615.10.9100, 9903.01.24; 9903.85.07; 9903.88.15, 3.1% + 20% + 10% + 50% aluminum content, “Table, kitchen or other household articles and parts thereof, of aluminum: Other: Other.” |
| Item: The item is a portable fire pit. The wood-fueled outdoor fire pit is to be placed on the ground and is collapsible. The item includes a spark screen, tools, a user’s manual, and a carrying backpack. All items are imported and packaged together for retail sale. The portable fire pit consists of a steel top ring. The inside body of the fire pit is made of steel. The base pan, ashpan, and legs are stainless steel. The outer body of the fire pit is made of aluminum. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |
N349567: The tariff classification of compact ethylene propylene diene monomer (EPDM) rubber sunroof seal from China
| HTS: 4016.93.1050, 9903.01.24, 9903.01.25, 9903.88.03, 2.5% + 20% + 10% + 25%, “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: A sunroof seal composed of compact EPDM rubber. The part is installed on both sides of a sunroof glass to prevent liquid and dust from passing through the sunroof frame. |
| Reason: N/A |
| Ruling Date: June 9, 2025 |