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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N349077: Country of origin determinations of a comforter; 19 CFR 102.21(c)(2); tariff shift
| Origin: China |
| Item: The subject article is identified as the JLA Home Down Alternative Comforter. The face and back fabrics are made of 100% polyester fiber, and it has a 100% polyester fiber fill. The manufacturing operations are as follows: In China, the polyester fabrics are formed. The polyester fiber fill is produced. The fabrics and fill are exported to Pakistan, where the fill is placed between the front and back fabrics and quilted. The comforter is cut, sewn, trimmed, inspected and packaged for export to the United States. |
| Reason: Since the subject comforter is composed of fabrics that were formed in China, it meets the (e)(2)(ii) rule, above, and is thus made in China. |
| Ruling Date: June 11, 2025 |
N349107: The country of origin of a monitor
| HTS: Vietnam or Thailand |
| Item: The merchandise under consideration is the Acer In-Plane Switching (IPS) monitor, Vero B7 series - B 277- G. These monitors receive data from an external source, then process and convert that data into physical output commands to display an image. The monitors are manufactured and assembled in Vietnam or Thailand. The main printed circuit board assembly (PCBA), which receives, decodes, and processes external video and audio, is manufactured by means of surface mount technology (SMT), which involves affixing electronic components to a bare printed circuit board (PCB) in Vietnam or Thailand. This SMT process involves affixing 16 active electronic components and 269 passive components to the main PCBA. After the completion of the SMT process, additional components, such as VGA/HDMI and Display Port (DP), are manually added to the PCBA in Vietnam or Thailand. Two additional printed circuit board assemblies for the computer monitor, the power supply PCBA and the keyboard PCBA are also manufactured in Vietnam or Thailand by means of the SMT process. The open cell assembly, which is composed of liquid crystal display (LCD), is performed in China. For the monitors manufactured and assembled in Vietnam, the open cell assembly and the backlight unit are assembled together to make a complete liquid crystal display module (LCM) in Vietnam. However, for the monitors manufactured and assembled in Thailand, the open cell assembly and the backlight unit are assembled together in China to make a complete LCM. The final element of the assembly process consists of the fastening of the main PCBA, the ancillary PCBAs, and the LCM module into the monitor’s chassis (cabinet), which is performed in Vietnam or Thailand. |
| Reason: The origin of the monitor is the country in which the underlying main PCBA (main board) is produced. Accordingly, the Vietnam or Thailand main board imparts the prominent character of the device, since it performs the primary and vital functions of the monitor. As a result, the country of origin of the subject monitor is the country where the main PCBA is manufactured, in this case either Vietnam or Thailand |
| Ruling Date: June 11, 2025 |
N349114: The tariff classification of a child’s boot from China, Vietnam, and the Philippines
| HTS: 6405.90.9060, 9903.01.24; 9903.01.25, 12.5% + 20% + 10%, “other footwear: other: other: other.” |
| Item: A child’s boot that covers the ankle but not the knee. It has a clear molded rubber/plastic upper and a molded rubber/plastics outer sole. The textile sock lining is decorated with hearts on a rainbow-colored background that shows through the clear upper. Two heart-shaped handles are attached by rivets at the topline. It has flocked leather material covering 51% of the external surface area of the rubber/plastic outer sole touching the ground. The thick flocking completely obscures the material underneath and is considered the constituent material of the outer sole. The boot will be manufactured in China, Vietnam, and the Philippines. |
| Reason: N/A |
| Ruling Date: June 11, 2025 |
N349208: The tariff classification of Basic Violet Dye 111 from China
| HTS: 3204.13.8000, 9903.01.24; 9903.01.32; 9903.88.03, 6.5% + 20% + 10% + 25%, “Synthetic organic coloring matter, whether or not chemically defined; preparations as specified in note 3 to this chapter based on synthetic organic coloring matter; synthetic organic products of a kind used as fluorescent brightening agents or as luminophores, whether or not chemically defined: Synthetic organic coloring matter and preparations based thereon as specified in note 3 to this chapter: Basic dyes and preparations based thereon: Other: Other.” |
| Item: Basic Violet Dye 11:1 is a yellow-brown powder. The assigned Chemical Subtract Service (CAS) number is 73398-89-7. Basic Violet Dye 11:1 is a fluorescent dye primarily used as a colorant in commercial applications such as in ink production and dyeing materials like cotton, wool, and silk. It is a cationic dye from the Xanthene family, known for its bright pink/red color and strong green fluorescence when dissolved in water. |
| Reason: N/A |
| Ruling Date: June 11, 2025 |
N349234: The tariff classification of a robotic vacuum display model from China
| HTS: 3926.90.9989, 9903.01.24; 9903.01.25; 9903.88.15, 5.3% + 20% + 10% + 7.5%: “[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 non-functional display model of a Roomba robotic vacuum cleaner. It is constructed from molded plastic and contains no internal mechanical or electronic components. It is intended solely for display purposes in retail environments. The product is a hollow plastic shell designed to replicate the aesthetic and physical appearance (including size, shape, and finish) of a Roomba model. It allows customers to visually inspect and physically handle the unit, but it cannot perform any vacuuming or other functional operations. |
| Reason: N/A |
| Ruling Date: June 11, 2025 |
N349267: The tariff classification of an edible biscuit spoon from Belgium
| HTS: 1905.90.9090, 9903.01.25, 4.5% + 10%, “communion wafers, empty capsules of a kind suitable for pharmaceutical use, sealing wafers, rice paper and similar products…other…other…other.” |
| Item: The subject merchandise is described as an edible biscuit spoon which will be sold to ice cream parlors for use as a zero-waste alternative to traditional disposable spoons. The edible spoons have an appearance similar to a small spoon/spatula, and measure approximately 8.3 cm. in length, 1.5 cm. in width and are 1 cm. thick. The edible spoons are designed to be fully edible, offering both a functional and sustainable solution for serving ice cream. The edible spoons are said to be primarily composed of wheat flour, in addition to potato flakes, glucose syrup, salt, sunflower oil, water, sugar, antioxidants and sucralose. The edible spoons are manufactured by using a solid and elastic dough created by combining the ingredients in an industrial dough mixer. |
| Reason: N/A |
| Ruling Date: June 11, 2025 |
N349310: The country of origin of a plastic cellphone case from China
| Origin: China |
| Item: The product under consideration is described as a mobile phone case. It is designed to cover and safeguard a cellphone from physical damage such as scratches, drops, and impacts. This case is made from a combination of polycarbonate (“PC”) and thermoplastic polyurethane (“TPU”) plastic. The case covers the back, sides, and corners of the phone, but not the screen, and has a cutout on the back for the phone’s camera. It also features a built-in kickstand. All components are sourced from China except the protective film and paper packaging which will be produced in Thailand. The TPU resin and PC plate are molded to shape in China. In Thailand, the molded case undergoes further machine processing to create the magnetic slot, the kickstand and magnet are added to the case, protective film is laminated to the case, and it is inspected and packaged. |
| Reason: The Chinese injection molded plastic components hold the basic nature of the finished case and the further processing performed in Thailand would not result in a substantial transformation as it would not become a new article, possessing a new name, character, or use. Therefore, the country of origin for this mobile phone case will be China |
| Ruling Date: June 11, 2025 |
N349745: The tariff classification of an E-Paper Sign Device from Vietnam
| HTS: 8543.70.9860, 9903.01.25, 2.6% + 10%, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” |
| Item: The merchandise under consideration is identified as the Electronic Paper Display (EPD) Smart Sign, which is an e-paper display. The subject device comprises a 32-inch EPD display, control printed circuit board assembly (PCBA), and a timing control board within a metal chassis. The device further incorporates Bluetooth and Wi-Fi connection capabilities and is powered by an internal rechargeable battery. The subject Smart Sign is used in commercial environments in order to display prices, promotions, and advertisements directly on the e-paper screen in order to replace paper promotional materials or signage. The user can install new content via the Bluetooth and/or Wi-Fi connection. |
| Reason: N/A |
| Ruling Date: June 11, 2025 |
N350018: The tariff classification of a safety bed rail from Taiwan
| HTS: 9403.20.0050, 9817.00.96, free, “Other furniture and parts thereof: Other metal furniture: Household: Other: Other.” |
| Item: The Smart-Rail SRS-S is an accessory bed rail designed to facilitate the user’s entry and exit from bed. It has two floor-standing supports (feet), a tubular metal frame in the form of a large rectangle that slides between the mattress and the mattress foundation, and a tether that extends from the far side of this large rectangular frame and latches onto the bedframe on the far side of the mattress—all designed to make the bed rail secure and enable it to hold up to 300 lbs. One side of the bed rail pivots out from the bed at a right angle (approximately 16 inches) for added versatility. Once installed, the exposed bed rail is 16.25" wide and can be adjusted to a maximum height of 27.25". It is made in Taiwan and weighs approximately 10 lbs. |
| Reason: The essential character of the subject bed rail is imparted by the steel frame, as it is overwhelmingly predominant and is the primary material responsible for the article’s function of providing support and stability to a person climbing into and out of bed. The subject bed rail is not the light-duty type used to keep a young child from falling out of bed, nor is it the heavy-duty type used in hospitals or nursing homes. However, a medium-duty bed rail such as this one, with robust construction, floor-standing stabilizer feet, a tethered mattress anchor and capable of supporting up to 300 lbs., will be used by a person suffering from a permanent or chronic physical impairment that substantially limits one or more major life activities, such as caring for oneself. Based on the foregoing, the secondary subheading 9817.00.96, HTSUS, is applicable |
| Ruling Date: June 11, 2025 |
N349001: The tariff classification of steel brackets from Japan
| HTS: 7326.90.8688, 9903.81.90; 9903.01.33, 2.9% + 10% + 50%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The items under consideration are described as steel brackets used to attach, fix, fit, connect, protect, bind, or stabilize separate articles in semiconductor manufacturing equipment. There are five distinct bracket types for consideration: 1) Stainless steel brackets to hold a photo sensor in the furnace door. 2) Steel brackets that are bolted to the exhaust control rack, beams, and a gas box. 3) Stainless steel brackets to hold and align vacuum piping. 4) Stainless steel brackets that attach to the bracket of the regulator and support two pressure readouts. 5) Stainless steel brackets to hold the hard drive on the system controller. |
| Reason: N/A |
| Ruling Date: June 10, 2025 |