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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N349019: The country of origin of a gas-powered mini dirt bike
| Origin: Vietnam |
| Item: A dirt bike powered by a 196cc gas powered spark-ignition internal combustion engine. The specific specifications for the B200R are the following: Single cylinder air-cooled 4-stroke Displacement: 196cc Rated Power: 4.85KW/3600rpm (6.5 hp) Max Torque: 9.76 ft-lbs/2500 rpm Weight: 34 lbs. Ignition System: Non-contact Transistorized Ignition (TCI) Start Mode: Recoil pull start Fuel Tank Capacity: 3.5 liters (0.93 gallons) All bike frame manufacturing and assembly occurs in Vietnam. The stamped tubular parts of the frame are fabricated and assembled by welding. Once fully assembled, the bike frame assembly is exported to China for further processing. |
| Reason: The culmination of production processes performed in China to the Vietnamese frame and fork does not substantially transform the frame. Accordingly, the merchandise will be a product of Vietnam. |
| Ruling Date: June 12, 2025 |
N349167: The tariff classification of wheelchairs from China
| HTS: 8713.10.0000, 9903.01.24; 9903.01.25; 9817.00.96, free, “Invalid carriages whether or not motorized or otherwise mechanically propelled: Not mechanically propelled.” |
| Item: The TPM-CCC transport wheelchair provides a seating position that maintains a lower center of gravity which provides a sense of greater stability. The footplates rest flat and flush to the floor during transfer, eliminating the bending efforts required by healthcare staff when dealing with conventional footrests. The patented Powered Assist Lift (PAL) raises the patient’s center of gravity until it’s centered over the legs, mimicking the biomechanics of standing from a seated position. Patients can stand with less effort and stress on staff is reduced when assistance is required. In addition, the chair is equipped with a 10-button control handheld unit controller that also reclines the seat to place the patient into a more comfortable and secure range of semi-reclined transit positions. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349241: The tariff classification of a silicone plastic plug and seal from Mexico
| HTS: (1) 3926.90.4590, 3926.90.9989; 9903.01.27, 3.5%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [g]askets, washers and other seals: [o]ther.” (2) 3926.90.9989, 3926.90.9989; 9903.01.27, 5.3%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” |
| Item: The first item is described as a “Mini UMNL Cavity Plug Seal,” which is a small plug designed to block off an empty cavity in a Universal MATE-N-LOK (UMNL) electrical connector where a wire is not being used. It measures 4.1 millimeters in diameter at its widest point and is 7 millimeters long. The second item is described as a “6P Interface Seal,” which is a component used in six position (6P) electrical connectors and is specifically designed to prevent moisture, dust, and other contaminants from entering the connection area. It measures 0.8 inches by 0.55 inches. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349255: The country of origin of electric and gas-powered go-karts
| Origin: China |
| Item: The items have been identified as two (2) styles of go-karts; model 1 is powered by electricity, while model 2 is powered by gasoline. The majority of the go-karts are manufactured in China with Chinese components, the frame, a core component, is wholly manufactured in Vietnam and then shipped to China for additional processing. |
| Reason: Since the bulk of the go-karts is sourced from China, and the frame, while significant, does not impart the same level of importance, the country-of-origin of models 1 and 2 is China. |
| Ruling Date: June 12, 2025 |
N349262: The tariff classification of steering coupler from South Korea
| HTS: 8708.94.7550, 9903.94.05; 9903.01.33, 2.5% + 25% + 10%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Steering wheels, steering columns and steering boxes; parts thereof: Parts: Other: Other.” |
| Item: The merchandise under consideration is identified as a Damping Coupler, which is described as a flexible-type coupling composed of hubs and rubber plates. The coupler is designed to be used within a steering system in a vehicle. It is attached to the electric motor, which is then connected to the reduction gearbox within a steering system. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349269: The tariff classification of a grommet and seals of silicone plastic from Mexico
| HTS: (1) 3926.90.9989, 9903.01.01, 9903.01.27, 5.3%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” (2) 3926.90.4590, 9903.01.01, 9903.01.27, 3.5%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [g]askets, washers and other seals: [o]ther.” |
| Item: The first item is described as a “6 Way Grommet,” which is designed to guide and organize six cables or wires passing through it. The grommet measures 0.606 inches wide by 0.616 inches long by 0.275 inches deep. The second item is described as a “23 Position Amp Mating Seal,” which is a molded gasket that creates a seal to protect electrical connections from dust, water, and other contaminants. The seal measures 41.4 millimeters wide by 21.6 millimeters long by 1.5 millimeters deep. The third item is described as a “Seal Front 3 Size 16 Contacts DT Series,” which serves as an environmental seal for Deutsch DT series electrical connectors. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349311: The country of origin of a hydraulically-powered injection molding machine
| Origin: Mexico |
| Item: The Engel T-WIN 11600/1460 series (T-WIN) is a hydraulically-powered, customizable injection molding machine designed to mass produce a wide range of medium to large-sized molded plastic products. Components from these units are manufactured in China, European Union (EU) countries, and Mexico. The complete T-WIN comprises four principal units: injection unit, clamping unit, frame, and electronics. |
| Reason: The nature of the processing performed in Mexico is not simple. These complex operations result in the individual component parts losing their separate identities to become a new article, i.e., a complete functioning injection molding machine. Therefore, the country of origin of the T-WIN 11600/1460 series injection molding machine will be Mexico. |
| Ruling Date: June 12, 2025 |
N349312: The country of origin of an electric-powered injection molding machine
| Origin: Mexico |
| Item: The Engel E-MAC 265/110 series (E-MAC) is a customizable electric-powered injection molding machine designed to mass produce high-quality molded plastic products. Components from these units are manufactured in China, European Union (EU) countries, and Mexico. The complete E-MAC comprises four principal units: injection unit, clamping unit, frame, and electronics. |
| Reason: The nature of the processing performed in Mexico is not simple. These complex operations result in the individual component parts losing their separate identities to become a new article, i.e., a complete functioning injection molding machine. Therefore, the country of origin of the E-MAC 265/110 series injection molding machine will be Mexico. |
| Ruling Date: June 12, 2025 |
N349346: The tariff classification of automotive brake calipers from Malaysia
| HTS: 8708.30.5090, 9903.94.05; 9903.01.33, 2.5% + 25% + 10%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories of bodies (including cabs): Brakes and servo-brakes; parts thereof: For other vehicles: Other.” |
| Item: The articles under consideration are five models of Brake Calipers, which are used in sedans and pick-up trucks. The function of the brake calipers is to convert hydraulic energy into mechanical force. When the driver presses the brake pedal, hydraulic fluid is pushed into the brake caliper, moving the piston. This action forces the brake pads against the brake disc, generating friction and enabling the vehicle to slow down or stop. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349366: The tariff classification, country of origin, and eligibility of the United States-Mexico-Canada Agreement (USMCA) of a chenille fabric from Canada
| HTS: 5801.36.0020, 9903.01.10; 9903.01.25, free + 25% + 10%, “Woven pile fabrics and chenille fabrics, other than fabrics of heading 5802 and 5806: Of man-made fibers: Chenille fabrics: Other.” |
| Origin: Canada |
| USMCA: No |
| Item: A woven fabric of crowfoot weave construction. The fabric is composed wholly of acrylic staple fibers and is woven with chenille yarns in the weft (filling) direction of the fabric. The fabric weighs 487.07 g/m2. There is no coating applied to the face or back of the fabric. The fabric will be imported in widths of 54 inches and will be used for upholstery. The manufacturing process for the fabric is as follows: Acrylic staple fiber is made and shipped from a non-USMCA region to the United States. The acrylic staple fibers are used to make a two ply yarn and chenille yarn in the United States. The two ply yarns and chenille yarns are shipped to Canada. The two ply yarns and chenille yarns are woven into a chenille fabric in Canada. The chenille fabric is then shipped to the United States. |
| Reason: The yarns of the subject fabric were formed in the United States. The fabric was manufactured in Canada, from two ply acrylic yarns classified in heading 5509, and chenille yarns classified in 5606. Since the fabric was formed in Canada, and since according to the above rule there was an applicable tariff shift as a result of a fabric-making process in Canada, as per the terms of the tariff shift requirements, the country of origin is conferred in Canada. As the chenille fabric is not produced entirely within one or more USMCA countries, the fabric is not considered originating under GN 11(b)(iv). Based upon the preceding analysis, the fabric does not qualify for preferential treatment under the USMCA. |
| Ruling Date: June 12, 2025 |