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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N348896: The tariff classification of the Level-Eye capacitance device from China
| HTS: 9026.10.2080, 9903.01.24; 9903.01.25; 9903.88.01, free + 20% + 10% + 25%, “Instruments and apparatus for measuring or checking the flow, level, pressure or other variables of liquids or gases (for example, flow meters, level gauges, manometers, heat meters), excluding instruments and apparatus of heading 9014, 9015, 9028 or 9032; parts and accessories thereof: For measuring or checking the flow or level of liquids: Electrical: Other.” |
| Item: The item under consideration is described as the Level-Eye capacitance device, which is a two-piece assembly that determines the cryogenic liquid level through “parallel plate capacitance.” The assembly starts with the capacitance wand, which is a stainless-steel tube within a tube. The dielectric measurement between the two tubes is dependent on the cryogenic liquid level that results in a modified signal sent to the Level-Eye head unit. The Level-Eye head unit is attached to the top of the wand via an electrode connector. This head unit then takes the measurement and converts it to a 0-100 percent scale that is displayed on the device screen, or a 4-20mA output signal that is utilized for telemetry (remote monitoring). The device measures the cryogenic liquid level in tanks ranging from 180 liters to 450 liters. |
| Reason: N/A |
| Ruling Date: May 20, 2025 |
N349135: The tariff classification of steel cores from South Korea
| HTS: 8202.39.0040, 9903.01.25, free + 10%, “handsaws, and metal parts thereof; blades for saws of all kinds (including slitting, slotting, or toothless saw blades), and base metal parts thereof: circular saw blades, and parts thereof: other, including parts: diamond sawblade cores.” |
| Item: The items under consideration are identified as steel cores. Each core is a circular steel disc upon which diamond segments are welded onto. The cores are supplied to diamond tool manufacturers to construct diamond circular sawblades. The steel cores will be imported in various diameters and thicknesses. The steel cores are fully prepared to accept the diamond segments at the time of importation. |
| Reason: N/A |
| Ruling Date: May 20, 2025 |
N348407: The tariff classification of steel body panels for semi-trailers from South Korea
| HTS: 8716.90.5060, 9903.01.25, 3.1% + 10%, “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Parts: Other: Other.” |
| Item: The items under consideration have been identified as steel composite panels used in the manufacturing of trailer body walls. The panels are composed of G90 galvanized Grade 80 steel, which are pre-painted with a polyester based paint. The panel core is made from 100% high-density polyethylene (HDPE), a thermoplastic polymer produced from the monomer ethylene. The panels and core are bonded together with an adhesive film pressed between rollers. |
| Reason: N/A |
| Ruling Date: May 19, 2025 |
N348539: The tariff classification of an effects pedal circuit board from China
| HTS: 8543.90.6800, 9903.01.24; 9903.01.25; 9903.88.01, free + 20% + 10% + 25%, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Other: Printed circuit assemblies: Other.” |
| Item: The merchandise under consideration is identified as the Tomkat Pedal Printed Circuit Board Assembly (PCBA), which is a specifically designed PCBA for use exclusively with the Tomkat Super Heavy guitar effects pedal. The subject PCBA is populated with various electrical components including transistors, diodes, capacitors, resistors and microcontrollers. The device is installed within the effects pedal in order to perform various tasks including the processing of signals from the guitar. |
| Reason: N/A |
| Ruling Date: May 19, 2025 |
N348567: The country of origin of a high speed cable
| Origin: Vietnam or Germany |
| Item: The merchandise under consideration is described as an 8-pair high speed cable. The subject cable consists of eight pairs of twinax wire conductors and a single drain wire wrapped in braiding, jacketing, and insulation. The cable is imported on reels and not terminated with connectors on either end. The subject cable is used as a high-speed data cable primarily used in data centers. The manufacturing process begins with silver-plated copper conductor wire from either Germany or Vietnam being imported into China. In China, the conductor wire is extruded to add a layer of insulation, creating an insulated core. Next, two insulated cores are wrapped together with aluminum-mylar shielding and a drain wire for grounding to create the twinax conductor. The twinax conductors are then shipped to India, where eight conductors are wrapped together with mylar and plastic tape and jacketed with a braided shield and a last layer of insulation. The finished cable is then put on a reel and prepared for shipment to the U.S. |
| Reason: The silver-plated copper conductor wire imparts the character of the finished device as it is the primary electrical component. The various processes performed in China and India, including wrapping and insulating, do not substantially transform the conductor into a new and different article of commerce. Accordingly, the origin of the 8-pair high speed cable will be Germany or Vietnam, depending on where the copper conductor wire is manufactured. |
| Ruling Date: May 19, 2025 |
N348607: The tariff classification of steel plywood clips and steel base brackets from China
| HTS: 7326.90.8688, 9903.01.24; 9903.81.90; 9903.01.33; 9903.88.03, 2.9% + 20% + 10% + 25% + 25%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The first items under consideration are described as steel plywood clips of various sizes. The plywood clips are pieces of steel which are first bent to a “U” shape. From the side walls, sections of steel are punched to shape and bent downward to form a parallel “U” in the opposite direction. When in use, the clips are designed to provide a gap between the horizontal edges of adjacent sheets of plywood. The clips are 100% steel with a galvanized zinc finish. The second items under consideration are described as steel base brackets to be imported in two sizes. The base brackets consist of a U-shaped section of steel with a threaded steel rod which extends below. When installed, the U-shaped bracket is fastened to a wooden post above, and the threaded rod is fastened with a nut and washer into a base material beneath. Functionally the base brackets form a secure connection to hold, support, and connect a wooden post to a base in various applications. The threaded rod component also allows for vertical adjustment of the connected post. The base brackets are 100% steel with a galvanized zinc finish. |
| Reason: N/A |
| Ruling Date: May 19, 2025 |
N348698: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: 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 one or two optical fibers depending on the model number. The fiber core is enclosed within a jacket and the cable assembly is terminated at each end with a fiber optic connector. The subject cables are used within various telecommunications industries to transfer optical data signals. The manufacturing process for all five 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 with plastic and aramid yarn. The ends are then prepared for the addition of the connectors. The Chinese originating 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 as their end use is predetermined, and they perform the primary function of transmitting the data signals. Based upon the facts presented, the origin of the patch cord assemblies will be the U.S. |
| Ruling Date: May 19, 2025 |
N348700: The tariff classification of a centrifuge feed tank from Canada
| HTS: 8479.89.9599, 9903.01.26, 9903.01.10, 2.5% + 25%, “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” |
| Item: The 342 Centrifuge Feed Tank Module (342 Module) is a processing unit that will be installed into the Nanushuk Processing Facility (NPF) in Alaska. The NPF will process oil deposits from the Nanushuk reservoir into sales quality oil. The 342 Module will be installed downstream from the Seawater Treatment Plant which provides seawater injection to subsurface reservoirs in the NPF. The 342 Module is the second stage of a gravitational separation process to separate solids and sediments from four upstream input flows. |
| Reason: N/A |
| Ruling Date: May 19, 2025 |
N348102: The tariff classification of shaped boards from China
| HTS: 4421.99.9880, 9903.01.24; 9903.01.63; 9903.88.03, 3.3% + 20% + 125% + 25%, “Other articles of wood (Other than bamboo): Other: Other: Other: Other: Other.” |
| Item: The sample submitted is a portion of a drawer side. It is constructed of rubberwood with a continuous groove that runs the length of the panel to accept a drawer bottom. The drawer sides measure 7’ in length by 4” high and 1/2” wide and will be cut to length after importation. |
| Reason: N/A |
| Ruling Date: May 8, 2025 |
N347486: The tariff classification of a Ball Marker 3 Piece Set from China
| HTS: 9506.39.0080, 9903.01.24; 9903.88.15, 4.9% + 20% + 7.5%, "Articles and equipment for general physical exercise…athletics, other sports…parts and accessories thereof: Golf clubs and other golf equipment; parts and accessories thereof: Other." |
| Item: The product consists of 3 metal ball markers and a magnetic hat clip. The metal golf ball markers are used in the game of golf to mark the position of golf ball when it is in the way of another player's shot. The magnetic hat clip is used to hold the metal golf ball markers for easy access when needed. The 3-piece Ball Marker Set is considered an accessory used in the sport of golf. |
| Reason: N/A |
| Ruling Date: Apr. 9, 2025 |