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:
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
N349587: Country of origin determination for a comforter 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: Pakistan |
| Item: The subject 7-piece comforter set, identified as “RH CARA,” consists of a comforter, two pillow shams, a flat sheet, a fitted sheet and two pillowcases. Each item in the set is made from 100% polyester microfiber woven fabric. The manufacturing operations for the RH CARA comforter set are as follows: In China, polyester microfiber fabric (face side of comforter and shams) is formed, dyed and printed. Dyed and printed polyester microfiber fabric (face side for comforter and shams) is exported to Pakistan. In Pakistan, polyester microfiber fabric (back fabric of comforter and shams) is formed, dyed and finished. Polyester microfiber fabric (sheets and pillowcases) is formed, dyed and finished. Elastic, polyfill, sewing thread, labels and packaging are formed. Fabric is cut and assembled by sewing to form comforter shell, pillow shams, sheets and pillowcases. Comforter is stuffed with polyester fiberfill, quilted and sewn closed. |
| Reason: In the case of the subject comforters and pillow shams, the country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Pakistan. As the fabric comprising the sheets and pillowcases is formed in a single country, that is Pakistan, the country of origin is conferred in Pakistan. |
| Ruling Date: June 13, 2025 |
N349626: Country of origin determination for a pillowcase; 19 CFR 102.21(c)(2); tariff shift
| Origin: Vietnam |
| Item: The subject merchandise consists of a set of two pillowcases constructed of 280 thread count, 100% cotton plain woven fabric. Each pillowcase is dyed. They are neither printed nor napped. The pillowcases consist of two panels sewn together on three sides. The fourth side is left open to allow for the insertion of a pillow. The manufacturing operations for the pillowcase are as follows: In Vietnam, Greige plain woven cotton fabric is formed. Greige plain woven cotton fabric is shipped in rolls to China. In China, Greige plain woven cotton fabric is de-sized, mercerized, bleached, dyed, calendared and preshrunk. The finished fabric is cut into panels and sewn to produce a pillowcase. The pillowcases are packaged in sets of two and exported to United States. |
| Reason: As the fabric comprising the pillowcases is formed in a single country, that is, Vietnam, country of origin is conferred in Vietnam. |
| Ruling Date: June 13, 2025 |
N349776: The tariff classification of alarm sensors from Thailand
| HTS: 8543.70.4500, 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: Electric synchros and transducers; flight data recorders; defrosters and demisters with electric resistors for aircraft: Other.” |
| Item: The first item is identified as the Vivint Door Window Sensor Long Range, which comprises a magnetic unit and a sensor unit that are designed to be used in conjunction with each other. The sensor unit is designed to be adhered to a door or window frame while the magnet is meant to be secured adjacent to the sensor unit on the window or door. The sensor detects the presence of the magnet and, when the door or window is opened moving the magnet away, the sensor sends a wireless signal to the main unit for the alarm system, alerting it to the open status. The second item is identified as the Vivint Motion Sensor, which consists of a passive infrared (PIR) sensor attached to a printed circuit board assembly (PCBA) within a plastic enclosure. The device is meant to be attached to a wall within a room and wirelessly connects, via radio signal, to an alarm panel. The sensor detects any change in infrared heat in a room, interpreting this change as the presence of an intruder. A signal is then generated and sent to the alarm panel, notifying the system of an intruder. |
| Reason: N/A |
| Ruling Date: June 13, 2025 |
N349827: The country of origin of cable assemblies
| Origin: Mexico |
| Item: Cable assemblies for use with video display units within an aircraft’s in-flight entertainment system. Both cables are constructed of multiple insulated conductors, bundled together and terminated at each end with specialized multi-pin video connector. The manufacturing process begins with the manufacture of the insulated conductors in Mexico prior to them being bundled together in the appropriate configuration. The finished bundled conductors are then shipped to China. In China, the conductor cables are cut to length before the ends are prepared for the connectors. The ends are then attached to the terminals within the internal connectors prior to the outer shell of the connector being added. The finished cable is then inspected, tested, and packaged for shipment to the U.S. |
| Reason: The Mexican conductor cable imparts the character of the finished assembly. The processes performed in China, including adding the connectors, is not significantly complex in order to result in a substantial transformation of the conductors into new and different articles of commerce. |
| Ruling Date: June 13, 2025 |
N349869: The country of origin of an audio amplifier
| Origin: Thailand |
| Item: The item concerned is an audio amplifier (Harbinger VARI V3412 Audio Amplifier/Speaker). This device is a portable sound system with advanced electronic features for amplification and sound reproduction of instruments and voice. It includes a pre-amp and sound mixer that supports up to five simultaneous input sources. The subject amplifier consists primarily of a back panel (chassis) that houses a variety of printed circuit board assemblies (PCBAs) that are used to provide the amplification and electronic functionality of the product. The chassis assembly is combined with speakers and enclosed within an outer housing. Manufacturing Process for the Harbinger VARI V3412 Amplifier: The back panel (chassis assembly), which houses the electronics needed to provide the amplification and all other electronic functionality, is manufactured within Thailand. The back panel incorporates various PCBAs, battery management components, knobs, and wire/cables. All the PCBAs in the subject amplifier will be manufactured in Thailand. The back panel chassis assembly is then sent to China. Within China, the back panel assembly will be connected to Chinese origin speakers and then encased within a China origin housing. |
| Reason: The character of the finished amplifiers is imparted by the back panel chassis assembly, which would be considered the dominant component. The back panel chassis assembly is manufactured within Thailand from various PCBAs which are also manufactured within Thailand. The subsequent manufacturing/assembly steps undertaken in China do not affect a substantial transformation. The back panel chassis assembly retains its own identity with a predetermined end use. Therefore, since a substantial transformation does not occur as a result of the Chinese processing, the country of origin of the finished Harbinger VARI V3412 Audio Amplifier/Speaker will be Thailand for origin and marking purposes. |
| Ruling Date: June 13, 2025 |
N349995: The classification of calendars from South Korea
| HTS: 4910.00.6000, 9903.01.31, free + 10%, “Calendars of any kind, printed, including calendar blocks: Other.” |
| Item: The first item is a complete, folded paper calendar with printed calendar pages and photographic images. The calendar is printed by a digital color printing process. |
| Reason: N/A |
| Ruling Date: June 13, 2025 |
N350001: The country of origin of carbide hole saws
| Origin: Switzerland and U.S. |
| Item: The products under consideration are carbide hole saws of various diameters. Each hole saw consists of a steel body with tungsten carbide tipped teeth. The other end of the hole saw incorporates a cap and adaptor. The adaptor enables the hole saw to connect to the mandrel system of a power tool. The subject carbide hole saws will be produced in Switzerland, the United States, and China under 5 production scenarios. Under the first 4 production scenarios, steel strip material on coil will be purchased from Germany or Austria and manufactured into the carbide hole saws in Switzerland and China. Under Production Scenario 5, the steel strip material on a coil will be purchased from the U.S. |
| Reason: The steel strip material on coil is substantially transformed by milling or laser cutting saw teeth into it, welding the tungsten carbide tips onto the teeth, and grinding the tungsten carbide tips to their final cutting shape. The creation of the carbide-tipped teeth imparts the essence of the finished saw blades. Accordingly, under production scenarios 1 through 4, the country of origin of the carbide hole saws is Switzerland. Under production scenario 5, the country of origin of the carbide hole saws is the United States. |
| Ruling Date: June 13, 2025 |
N350028: The country of origin of veneer edge banding
| Origin: China |
| Item: The product under consideration is veneer edge banding. In the proposed manufacturing scenario, the veneers are peeled from logs in China. The veneers will then be shipped to Belgium where they are cut to standardized widths. The veneers will be end-jointed to create longer lengths. A thin fleece backing will be applied to the veneer for stabilization. The veneers will be subjected to quality control measures and then fed through a sanding and finishing line multiple times, during which a UV-cured clear coating will be applied to the surface. After final trimming, the edge banding is complete. |
| Reason: There are no operations that take place in Belgium that result in a product that is something other than veneers. The original product from China – veneers – remain veneers even after the manufacturing operations. Therefore there is no substantial transformation that takes place in Belgium. The country of origin of the edge banding is China. |
| Ruling Date: June 13, 2025 |
N341273: The tariff classification of yarns from China and Turkey
| HTS: (Article 1) 5406.00.1040, 9903.01.25, 9903.01.24, 9903.88.03, 7.5% + 20% + 10% + 25%, “Human-induced filament yarn (other than sewing thread), put up for retail sale: Synthetic filament yarn: Of polyesters.” (Article 2) 5606.00.0090, 9903.01.25, 9903.01.24, 9903.88.03, 8% + 20% + 10% + 25%, “Gimped yarn, and strip and the like of heading 5404 or 5405, gimped (other than those of heading 5605 and gimped horsehair yarn); chenille yarn (including flock chenille yarn); loop wale-yarn: Other.” (Article 3) 5511.10.0030, 9903.01.25, 7.5% + 10%, “Yarn (other than sewing thread) of man-made staple fibers, put up for retail sale: Of synthetic staple fibers, containing 85 percent or more by weight of such fibers: Acrylic or modacrylic.” (Article 4) 5207.90.0000, 9903.01.25, 9903.01.24, 9903.88.03, 5% + 20% + 10% + 25%, “Cotton yarn (other than sewing thread) put up for retail sale: Other.” |
| Item: Article 1, Feels Like Cuddles, is a yarn composed of 100% polyester filament fiber. The yarn is for retail sale and is intended for knitting and crocheting. The country of origin is China. It is a fancy yarn consisting of a knit chain stitch holding sixteen yarns together. The textured yarn is composed wholly of polyester multifilament fibers with a twist created from producing the fancy yarn. The sample is not a gimped, boucle, chenille, or loop wale yarn. The fibers are not carded, combed, or otherwise processed for spinning. The yarn weighs 154.9 grams and is not considered roving. Article 2, Feels Like a Dream, is a yarn composed of 100% nylon filament fiber. The yarn is for retail sale and is intended for knitting and crocheting. The country of origin is China. The yarn consists of four single ply yarns that are twisted together to form a four-ply yarn. Each single-ply yarn is a chain stitch/warp knit construction with additional fibers inserted and protruding along the chain stitches. The width of the chain stitches is approximately 1 millimeter and the length of the fibers protruding along one side of the chain stitches is approximately 1 centimeter. Each single ply yarn is considered a chenille yarn. The yarn weighs 101.2 grams and has a linear density of 4792 denier. Article 3, Feels Like Sherpa, is a yarn for retail sale and is intended for knitting and crocheting. The country of origin is Turkey. It is a 3-ply yarn consisting of three components: one 1-ply textured acrylic staple roving yarn that is twisted to a one 1-ply polyester multifilament yarn and a one 2-ply polyester multifilament yarn. The overall fiber content by weight is 92.8% acrylic and 7.2% polyester. The roving fibers have been carded, combed, and are parallel with a slight twist. The ball of yarn weighs 100.1 grams. Article 4, Tom Daley – Made with Love – The Cottony One, is a yarn for retail sale and is intended for knitting and crocheting. The country of origin is China. It is a cable yarn composed of 58.4% cotton and 41.6% acrylic staple fiber. The skein of yarn weighs 103.5 grams and has a decitex of 6041.7. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |
N349011: The tariff classification of wheelchairs from Canada
| HTS: 8713.10.0000, 9903.01.26; 9817.00.96, free, “Invalid carriages whether or not motorized or otherwise mechanically propelled: Not mechanically propelled.” |
| Item: The first item under consideration is the BRODA - Elite Positioning Wheelchair. The second item under consideration has been identified as the BRODA - Encore Pedal Wheelchair. The third item under consideration has been identified as the BRODA - Revive Shower Commode Wheelchair. |
| Reason: N/A |
| Ruling Date: June 12, 2025 |