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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N349404: The tariff classification of a horticultural protection system from Germany
| HTS: 7308.90.9590, 9903.81.90; 9903.81.91, free + 50% + 10%, “Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The VOEN Covering System is a complete, unassembled horticulture structural protection system that will be assembled after importation into the United States. The covering system is comprised of galvanized steel poles, cables, anchors clips, tensioners, and anchor plates. A woven, high-density polyethylene (HDPE) mesh is secured to the top of the steel structure and acts as a protection barrier, which allows self-ventilation. |
| Reason: As the covering system includes steel structure components and plastic mesh, both of which are classifiable in different headings, it is a composite good in accordance with GRI 3(b). The steel components assemble to form the structure of the covering system. Therefore, the essential character of the unassembled covering system is imparted by the steel structure, which is classified in heading 7308, Harmonized Tariff Schedule of the U.S. |
| Ruling Date: June 12, 2025 |
N349417: Country of origin determination for a bed pillow; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.13; De Minimis
| Origin: India |
| Item: The subject merchandise, the “Soft Surrounded Feather Pillow,” is a bed pillow with an outer surface of 100% cotton woven fabric and a sewn-in inner fabric of 100% polyester woven fabric. The polyester woven fabric is sewn into the outer seam. The space between the polyester fabric and cotton fabric is filled with 1.5 denier polyester staple fiber. The space within the polyester woven fabric is filled with 95% grey duck feather and 5% down. The pillow measures 20 X 28 inches. The manufacturing operations for the pillow are as follows: In India, cotton woven fabric (outer shell) is formed. Cotton woven fabric (outer shell) is exported on rolls to China. In China, cotton woven fabric (outer shell) is bleached with down proof treatment. Polyester woven fabric (inner fabric) is formed and bleached with down proof treatment. Polyester staple fiber is manufactured. Grey duck feather and down are sourced. Fabrics are cut and assembled by sewing. The outer chamber is stuffed with polyester staple fiber. The inner chamber is stuffed with grey duck feather and down. The outer pillow shell is sewn closed. The finished pillow is packaged and shipped to the United States. |
| Reason: The polyester fabric represents 3.2% of the total weight of the pillow. Therefore, as the polyester fabric does not constitute more than 7% of the total weight of the pillow, the fabric is disregarded in determining the country of origin of the pillow. As the remaining fabric, the cotton woven fabric, is formed in a single country, that is, India, as per the terms of the tariff shift requirement, country of origin is conferred in India. |
| Ruling Date: June 12, 2025 |
N349420: The tariff classification of an electric wheelchair, manual wheelchair, and mobility scooter from China
| HTS: (1), (2) and (3) 8713.90.0060, 9903.01.24, 9903.01.25, 9817.00.96, free, “Carriages for disabled persons, whether or not mechanically propelled: Other: Other.” (4) 8713.10.0000, 9903.01.24, 9903.01.25, 9817.00.96, free, “Carriages for disabled persons, whether or not mechanically propelled: Not mechanically propelled.” (5) 8703.90.0100, 9903.01.24, 9903.01.25, 9903.91.03, 2.5% + 20% + 10% + 100%, “Motor cars and other motor vehicles principally designed for the transport of persons (other than those of heading 8702), including station wagons and racing cars: Other.” |
| Item: The first item under consideration is the IQ-9000 Remote Controlled Electric Wheelchair (“IQ-9000”). The IQ-9000 is a foldable, lightweight chair featuring a remote-control system for user or caregiver operation, designed for ease of transport and daily use. The second item is the Glide Care G-5 Lightweight Foldable Electric Wheelchair (“Glide Care”). The Glide Care is a travel-friendly option designed for quick folding, compact storage, and maneuverability, making it well-suited for use by persons with mobility impairments. The third item is the Phoenix Carbon Fiber Electric Wheelchair (“Phoenix”). The Phoenix is a lightweight foldable wheelchair that is designed to facilitate travel. The fourth item has been identified as the X-1 ComfyGO Lightweight Manual Wheelchair with Quick-Detach Wheels (“X-1”). The X-1 is a lightweight, non-motorized wheelchair designed for everyday use. The fifth and final item is the Z-4 Ultra-Light Electric Mobility Scooter with Quick Detach Frame (“Z-4”). The Z-4 is a compact, battery-powered scooter specifically designed for individuals with mobility impairments who require an assistive device for daily travel. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349493: The tariff classification of cooling modules from Canada
| HTS: 8419.50.5000, 9903.01.26, free, “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: Heat exchange units: Other.” |
| Item: The merchandise under consideration is the 431, 433, and 435 Lift Injection Gas ESD Modules that are incorporated into the Nanushuk Processing Facility, a modular plant currently under construction in Alaska. When construction is complete, this facility will process oil deposits from the Nanushuk reservoir into sales quality oil. All three modules are identical in configuration and installed with sequential compressor modules (i.e., module numbers 432, 434, and 436) in the plant. The function of the lift injection gas modules is to cool compressed gas within two gas intercoolers in each module. The intercoolers are configured as stainless-steel plate and shell heat exchangers, where compressed gas flows into the shell side of the unit while a cooling medium flows through the plate side of the heat exchanger. The two fluids do not mix as they move through the intercooler and the compressed gas exits the module with a lower temperature. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349509: The tariff classification of a plastic water bottle from China
| HTS: 3924.10.4000, 9817.95.05, 3.4%, “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Tableware and kitchenware: Other.” |
| Item: The merchandise under consideration is a plastic water bottle. It is a three-dimensional plastic drinking vessel with a straw. It measures approximately 5 inches in height and has a diameter of 4.50 inches, as measured at its widest points. The round, white water bottle showcases the facial features of Jack Skellington, the skeletal character from Disney’s “The Nightmare Before Christmas” movie. The lid includes a black straw, and a removable, non-adjustable polyester webbing hand strap attached with plastic clips located on each side of the lid. The plastic water bottle is made of a single-walled plastic with no vacuum properties. The volume capacity is 18 ounces. The article glows in the dark and is intended for household use for children ages 4 years old and up. |
| Reason: The plastic water bottle incorporates a motif associated with Halloween. Halloween is a recognized holiday. As such, the item also meets the terms of subheading 9817.95.05, as it is a utilitarian article in the form of a three-dimensional representation of a symbol or motif associated with a specific holiday in the United States. |
| Ruling Date: June 12, 2025 |
N349537: The tariff classification and country of origin of a power supply
| HTS: 8504.40.9540, 9903.01.24; 9903.01.25; 9903.88.03, free + 20% + 10% + 25%, “Electrical transformers, static converters…: Static converters: Other: Rectifiers and rectifying apparatus: Power supplies: Other.” |
| Origin: China |
| Item: The merchandise under consideration is the SFP800 LED Sportlighting Driver (Driver), which is described as a cast aluminum enclosure containing a switching mode power supply (SMPS), a surge protection device (SPD), two electrical connectors, and electrical wires. In use, the Driver supplies DC power to LED lighting systems by converting AC input voltage to a regulated DC output. The Driver has a maximum output power of 800 W. The subject Driver is assembled in Vietnam by mounting the Chinese origin SMPS and SPD into the Vietnamese origin aluminum enclosure, attaching the German origin electrical connectors, and attaching wires, gaskets, and plugs of various origins. The Driver is tested, calibrated, and packaged for export to the United States. |
| Reason: The assembly of the SMPS and SPD in Vietnam by inserting and attaching with fasteners does not substantially transform the power supply and/or surge protector into a new article in name or function. Furthermore, the SMPS establishes the core function of the Driver because it is the article within the assembly that is converting and supplying power to the LED system. As a result, the SFP800 LED Sportlighting Driver is considered a product of China at the time of importation into the United States. |
| Ruling Date: June 12, 2025 |
N349830: The tariff classification of a fiberboard tray from Vietnam
| HTS: 4420.90.8000, 9903.01.25; 3.2% + 10%, “Wood marquetry and inlaid wood; caskets and cases for jewelry or cutlery and similar articles, of wood; statuettes and other ornaments, of wood; wooden articles of furniture not falling within chapter 94: Other: Other.” |
| Item: The product under consideration is a round, handled tray measuring 11 inches in diameter (13 inches across tray and handles) and 2.75 inches high. The tray is made from medium density fiberboard (MDF). The handles on either side are made of metal wire. The tray is coated and printed with the expression “Happy Harvest”. The included label identifies that the tray is not for use with food. There are no hangers for attachment of the tray to a wall. The tray is used for decoration or for holding trinkets. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349886: The tariff classification of conversation cards from China
| HTS: 4911.99.6000, 9903.01.22; 9903.01.31; 9903.01.32; 9903.88.15, free, “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 conversation cards titled “Delve Deck.” The deck contains more than 100 cards that are printed with questions and topics to guide conversation between two or more people. The cards measure approximately 2” by 3.5”. An example of a conversation starter is “What do you wish you didn’t care about?” The cards are packaged in a rigid paperboard box. The cards are printed lithographically. |
| Reason: Merchandise classifiable under subheading 4901.99.0010, Harmonized Tariff Schedule of the U.S., constitutes “any information or informational materials” encompassed by 50 U.S.C. § 1702(b)(3). Accordingly, such merchandise is exempt from additional duties under Executive Order 14195 pursuant to head 9903.01.22, HTSUS. |
| Ruling Date: June 12, 2025 |
N349896: The tariff classification of the iConnect tablet accessories from China
| HTS: (1), (2), (3) and (4) 8473.30.5100, 9903.01.24; 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of heading 8470 to 8472: . . . Parts and accessories of the machines of heading 8471: Not incorporating a cathode-ray tube: . . . Other." (5) 3926.90.9989, 9903.01.24; 9903.01.25, 9903.88.15, 3.5% + 20% + 10% + 7.5%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” |
| Item: The first item under consideration is identified as the CONNECT PRO Case Air11 M3 BK, which is described as a plastic housing incorporating an integrated wireless charging module on the rear, a USB-C plug integrated into the interior bottom, and an external dock connector on the rear. The second item under consideration is identified as the CONNECT PRO Case iPadA16 BK-V3, which is described as a plastic housing incorporating an integrated wireless charging module on the rear, a USB-C plug integrated into the interior bottom, and an external dock connector on the rear. The third item under consideration is identified as the C-PRO UTILITY CASE 11PRO M4 GN, which is described as a plastic housing incorporating an integrated wireless charging module on the rear, a USB-C plug integrated into the interior bottom, a top bezel cover, and an external dock connector on the rear. The fourth item under consideration is identified as the CONNECT PRO Case iPad A16 BK, which is described as a plastic housing incorporating an integrated wireless charging module on the rear, a USB-C plug integrated into the interior bottom, and an external dock connector on the rear. The fifth item under consideration is identified as the CONNECT OverSleeve Rugged, which is described as a plastic sleeve designed to fit around an iPort CONNECT and is intended to provide physical protection to the iPort CONNECT and to the tablet PC placed within the iPort CONNECT. This protective sleeve does not have charging or interconnection capabilities and is compatible with both the CONNECT PRO and CONNECT Cases for the tablet PC, providing enhanced durability for retail and commercial environments. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349918: The tariff classification of paint samples from Canada
| HTS: 4911.10.0080, 9903.01.12; 9903.01.31, free, “Other printed matter, including printed pictures and photographs: Trade advertising material, commercial catalogs and the like: Other.” |
| Item: The first is identified as an Architect Kit, which contains 9 fan decks of paint samples, each connected by a metal rivet. Each card is printed with a paint color and identifying information such as paint name and brand information. The second item is a brochure measuring approximately 8.5” by 11”. The three-fold brochure is printed with information about the brand, lighting, color selection, color undertones, and the like, and opens further to reveal dozens of paint sample colors. The third item is a fan deck consisting of many cards, each printed with seven colors and paint names on one side and brand and use information on the back. Like the fan decks above, these are connected with a metal rivet. The paint colors and product information are lithographically offset printed. The paint colors are coated with a substance that is formulaically similar to printing ink in order to simulate the finishes of the paint, from flat to gloss. The purpose of the paint samples is to select paint colors, but ultimately to sell a brand of paint to the consumer. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |