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.
N349598: The tariff classification of foam pads for passenger vehicles from South Korea
| HTS: 8708.29.5160, 9903.94.05; 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.” |
| Item: The merchandise under consideration is referred to as CVA RR Carpet EPP Pad, which is a foam pad that goes under the carpet assembly of a passenger vehicle and it is composed of 100% Ethylene Propylene Copolymer. The component is precisely molded for installation beneath the carpet assembly, which will ultimately go on top of the metal floor pan within a passenger vehicle. The molded piece is used to reduce the road noise and vibration transmitted from the underside of the vehicle. |
| Reason: N/A |
| Ruling Date: June 18, 2025 |
N349622: The tariff classification of turbine nozzle castings from South Korea
| HTS: 8411.91.9085, 9903.01.25, free + 10%, “Turbojets, turbopropellers and other gas turbines, and parts thereof: Parts: Of turbojets or turbopropellers: Other: Parts of aircraft turbines: Other.” |
| Item: The items under consideration have been identified as two (2) turbine nozzle castings, used in aircraft. Part one is a “Stage 1” turbine nozzle casting. These castings will be further machined to make stage 1 turbine nozzles for gas turbines, which are installed in Boeing B737 aircraft. Part 2 is a “Stage 2” turbine nozzle casting. These castings will be further machined to make stage 2 turbine nozzles for gas turbines, which are installed in Boeing B737 aircraft. The main function of turbine nozzles is to direct hot airflow from combustor to turbine blades so that the blades can be rotated with maximum efficiency. The turbine nozzles will be attached to turbine case with bolts/nuts. |
| Reason: N/A |
| Ruling Date: June 18, 2025 |
N349718: The tariff classification of LED lamps from China
| HTS: 8539.52.0030, 9903.01.24; 9903.01.25, 2% + 20% + 10%, “Electrical filament or discharge lamps, including sealed beam lamp units and ultraviolet or infrared lamps; arc lamps; light-emitting diode (LED) light sources; parts thereof: Light-emitting diode (LED) light sources: Light-emitting diode (LED) lamps; Of a type specified in statistical note 7(c) to this chapter.” |
| Item: The merchandise under consideration is identified as the E26 screw and E27 screw. The E26 screw and E27 screw are light-emitting diode (LED) lamps that consist of a heat sink containing the LEDs and other electrical and electronic components with a lens. They are in PAR shape, and each have an E26 or E27 screw cap to be screwed onto a lighting fixture. The lamps utilize the LED technology providing light for exotic animals (such as reptiles, turtles, etc.) that are sometimes kept as pets or in zoos as display or educational animals. The E26 screw features the unique factor in use for the product’s Ultraviolet A radiation, which is an essential part of animal welfare for these exotic animals. The Ultraviolet output has been tested to harmonized standard IEC 62471, and the products are marked as “Risk Group 2”, which means that they are not a risk to humans due to natural photo-aversion. |
| Reason: N/A |
| Ruling Date: June 18, 2025 |
N349742: The country of origin of cameras
| Origin: South Korea |
| Item: The merchandise under consideration is the R13-series smart-metering cameras and the C01 smart compactor waste-metering camera. The R13 series smart waste-metering cameras are all variants of the same hardware, with slightly different plastic enclosures, optimized for different types of containers. According to the scenario provided, for all models the main printed circuit board assembly (PCBA) is created via surface-mount technology (SMT) processing in South Korea and the flash flexible printed circuit board (FPC), and the compact camera module (CCM) are attached to the PCBA in South Korea. This main assembly consists of adding the heat stake flash FPC to the camera carrier, connecting the flash FPC to the main PCBA, assembling it to the chassis, combining and locking the CCM into the camera using CCM mount screws, and routing and connecting the flex of the CCM to the main PCBA. In addition, programming and testing are done in South Korea. The main PCBA with the flash FPC and the CMM can capture and convert images when shipped to China. In China, the chassis is attached to the front housing, the battery is connected to the main board, and the camera is tested and packaged. |
| Reason: The main PCBAs, camera module, and flash FPC all contribute to the main functionality of the finished products relative to the functioning of the product because of the role of these PCBAs with camera module and flash FBC (e.g., capturing and converting images). Additionally, the assembly process performed in China would not substantially transform the PCBA with the camera module and flash FPC of South Korean origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the country of origin of the subject cameras is South Korea. |
| Ruling Date: June 18, 2025 |
N349756: The tariff classification of the “Dino Carry Case Play Set” from China
| HTS: 9503.00.0073, 9903.01.24; 9903.01.25; 9903.88.15, free + 20% + 10% + 7.5%, “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 article under consideration is a play kit. The plastic carrying case is a toy in the shape of a dinosaur with posable arms and mouth. It is 10.5 inches high by 22 inches wide and has a depth of 4.3 inches. The case features storage compartments that hold eight toy vehicles and four smaller dinosaur figures. Children will derive amusement by using the contents of the set to create their own dinosaur and car displays. The kit is principally designed for the amusement of children ages 3 and older. |
| Reason: N/A |
| Ruling Date: June 18, 2025 |
N349835: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: The merchandise under consideration is described as five models of a fiber optic patch cord assembly, which are further described as fiber optic cables that consist of a fiber optic core, which consists of 2, 8, 64, or144 optical fibers depending on the model number. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The subject cables are used within various telecommunications industries to transfer optical data signals. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and prepared for the addition of the connectors, which are sourced from China. The connectors are then assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S. |
| Reason: The fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce. Based upon the facts presented, the origin of the fiber optic patch cord assembly will be the U.S. |
| Ruling Date: June 18, 2025 |
N349836: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: The merchandise under consideration is described as five models of a fiber optic patch cord assembly, which are further described as fiber optic cables that consist of a fiber optic core, which consists of 8, 16, 12, or 32 optical fibers depending on the model number. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The subject cables are used within various telecommunications industries to transfer optical data signals. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and prepared for the addition of the connectors, which are sourced from China. The connectors are then assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S. |
| Reason: The fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce. Based upon the facts presented, the origin of the fiber optic patch cord assembly will be the U.S. |
| Ruling Date: June 18, 2025 |
N349860: The tariff classification of empty aluminum cartridges from France
| HTS: 7612.90.1090, 9903.85.07; 9903.01.33, 5.7% + 50%, “Aluminum casks, drums, cans, boxes and similar containers (including rigid or collapsible tubular containers), for any material (other than compressed or liquified gas), of a capacity not exceeding 300 liters, whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment: Other: Of a capacity not exceeding 20 liters: Other.” |
| Item: The items under consideration are described as empty aluminum cartridges for use with caulking guns. The cartridges are used in various industries such as automotive, construction, and public works. The rigid and tubular cartridges contain and protect substances such as mastic, glue, and sealant during transportation, storage, and use. On one end, the cartridges feature a protrusion with external threading of size M15 × 1.50 millimeters (mm). The opposite end of the cartridge may be shaped to a rolled rim, crimping flange, or straight rim. The subject cartridges are composed of 1070 aluminum alloy and are 46.8 mm in diameter by 215 mm in length. At importation, the aluminum cartridges will be empty and without accessory components. |
| Reason: N/A |
| Ruling Date: June 18, 2025 |
N349893: The country of origin of a temperature and pressure sensor
| Origin: Thailand |
| Item: The item under consideration is described as an automotive temperature and manifold absolute pressure (MAP) sensor. The sensor measures the temperature in the engine as well as the pressure within the engine’s intake manifold, which in turn provides information to the engine control unit (ECU) for optimal fuel delivery and ignition timing. In operation, the sensor measures the absolute pressure within the intake manifold, which is the pressure of the air entering the engine cylinders. The automotive temperature and MAP sensor includes a Chinese origin sensor head frame, which is the physical housing that encases the sensing components of the sensor, provides protection, and allows for the mounting of the various components. The pins, which serve as the essential connection points that enable both electrical and mechanical connections are also housed within the frame. The components from Thailand include the thermistor, printed circuit board assembly, glue, cover and O-ring. The manufacturing process begins in Thailand with the creation of the printed circuit board assembly using surface mount technology. Next, the thermistor is soldered to the board and the terminal is added. Then, the Chinese produced sensor head frame and other Thailand produced injection molded components are hot melted around the circuit board. The semi-finished product is then tested before the cover is glued into place. The O-rings are then added before the final performance testing, appearance inspection, and laser batching. Finally, the finished sensors are packaged for final shipment. |
| Reason: The Chinese sensor head frame is transformed in Thailand from an article of plastic to a complete automotive temperature and MAP sensor. The creation of the PCBA in Thailand using surface mount technology, along with the addition of the thermistor and other Thailand origin components transforms the Chinese sensor head frame into a new product having a distinctive name, character, and use. Therefore, the country of origin of the automotive temperature and MAP sensor is Thailand, which is where the majority of the components are manufactured, including the PCBA and thermistor, and the assembly process is performed. |
| Ruling Date: June 18, 2025 |
N349916: The tariff classification of remote radio head from Taiwan
| HTS: 8517.62.0090, 9903.01.32, free, “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network) … : Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” |
| Item: The item concerned is a remote radio head transceiver module, which is used in an Open Radio Access Network’s (O-RAN) 4G and 5G base stations. An O-RAN is a non-proprietary version of the Radio Access Network (RAN) system which allows interoperation between cellular network equipment provided by different vendors. A RAN is a critical component of the overall mobile network architecture, responsible for connecting user devices (such as smartphones) to the core network via wireless links. |
| Reason: N/A |
| Ruling Date: June 18, 2025 |