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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N349152: The tariff classification and country of origin of tin snips and aviation snips
| HTS: 8203.30.0000, 9903.01.25, free + 10%, “files, rasps, pliers (including cutting pliers), pincers, tweezers, metal cutting shears, pipe cutters, bolt cutters, perforating punches and similar handtools, and base metal parts thereof: metal cutting shears and similar tools, and parts thereof.” |
| Origin: Thailand |
| Item: The tin snips consist of two primary pieces, which are the left and right side of the tool. Each piece incorporates a handle with a hand/finger ring on one side and a cutting end on the other. The handles are joined by a pin near the cutting end, which provides a fulcrum, allowing the scissor action of the tool. The subject articles also have a comfort grip applied to the handles. Aviation snips are compound action snips that have a mechanical linkage that provides a greater advantage than the scissor design of tin snips. Accordingly, they can cut thicker metal than tin snips. The following are the manufacturing processes for the two tools: Tin snips: In Thailand, raw steel rods are heated and drop-forged to make the two primary pieces of the tool (i.e., the right and left side). Each of these pieces incorporates the handle on one side and the cutting edge on the other. The two pieces are die-cut, sandblasted, and deburred. They are then sent to China where a hole is drilled into each, the finger/hand holes are punched, and the pieces are heat-treated. The right and left sides are assembled using a Chinese origin screw and nut through the hole, and the comfort grip is applied over the handles. Aviation snips: In Thailand, raw steel rods are heated and drop-forged into the two rough shapes that make up the head of the snips. The head incorporates the cutting part of the tool, the fulcrum, and upper section of the handle. These two pieces are then die-cut into their overall shape and form and further sandblasted. Next, raw steel sheet is die-cut into a flat outline of the two lower handle sections. The disassembled head and handles are then sent to China where they are heat-treated and drilled with holes for assembly with screws and nuts. The lower handles are bent into their final form and the blades on the head are sharpened. They are then assembled using Chinese origin screws and nuts. Finally, the Vietnamese steel handles receive a comfort grip before retail packaging. |
| Reason: The raw steel is substantially transformed in Thailand into identifiable blanks of the finished tools. This includes drop-forging and die-cutting steel into the handles and jaws of the tin snips and aviation snips. These articles provide the principal characteristics of the finished tools, are dedicated for use as such, and cannot be used for any other purpose. The character of these articles remains unchanged after the manufacturing processes and assemblies that occur in China. Therefore, the country of origin of the tin snips and aviation snips is Thailand. |
| Ruling Date: May 21, 2025 |
N349257: The tariff classification of the Centrifuge Module (346 Module) from the United States
| HTS: 8421.19.0000, 1.3%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Centrifuges, including centrifugal dryers: Other.” |
| Item: The item under consideration is described as the Centrifuge Module (346 Module), which is a dual-level fully-integrated packaged unit designed to remove solids and sludge from process streams within the Nanushuk Processing Facility (NPF). It functions as a critical part of the overall waste treatment system and is delivered as a prefabricated, self-contained structure. The module includes four centrifuges, two centrate tanks, two centrate pumps, and all piping, valves, instrumentation, controls, and electrical systems required for operation, as well as the necessary inlet and outlet connections to interface with the facility pipe-rack. |
| Reason: N/A |
| Ruling Date: May 21, 2025 |
N348123: Classification and country of origin determination for polyester and cotton digitally printable canvas
| HTS: 5901.90.2000, 9903.01.25, 7% + 10%, “Textile fabrics coated with gum or amylaceous substances, of a kind used for the outer covers of books or the like; tracing cloth; prepared painting canvas; buckram and similar stiffened textile fabrics of a kind used for hat foundations: Other: Of man-made fibers.” |
| Origin: India |
| Item: The subject merchandise is described as “Poly Cotton Digital Canvas” intended to be used by commercial digital printers for printing wall displays, graphic displays, trade show advertising and miscellaneous commercial application. All of the styles of the polyester and cotton digital printer fabrics are constructed of a yarn dyed, woven textile fabric composed of 65% polyester and 35% cotton which is visibly coated on one surface with a plastic material composed of 55% acrylic, 10% titanium dioxide and 35% filler resin. All styles of the poly/cotton digital canvas fabrics will be produced in full rolls measuring 60 inches and 54 inches in width and 50 yards in length. The manufacturing process for the canvas is as follows: India Fiber is formed. Yarn is spun. Yarn is dyed. Fabric is woven. Fabric is coated on one side. Fabric is cut to size according to each style. The finished fabric is packaged on roll and shipped in bags from India to the United States. |
| Reason: Since all of the styles are wholly obtained or produced in a single country, that is, India, the country of origin is conferred in India. |
| Ruling Date: May 20, 2025 |
N348322: The country of origin of coil springs
| Origin: U.S. |
| Item: The items under consideration are described as coil springs for use in automotive suspensions. Coil springs control and relieve vibration, noise, and the impact transmitted into an automotive vehicle while driving. The subject coils springs are mainly composed of grade SAE 9254 silicon-chromium spring steel and will be imported in different sizes. Manufacturing of the coil springs begins in Korea with steel rod as the primary raw material. The rod undergoes cold processing operations which includes straightening, shot blasting, shearing, and polishing. The steel rod is shipped to the United States in diameters of 16.45 millimeters (mm) to 19.3 mm and in lengths of 1865 mm to 2815 mm. In the United States, the imported steel rod is heated in a furnace up to 980 degrees Celsius which causes physical changes in the steel and makes it malleable. Once heated, the steel rod is coiled around a mandrel according to a specified shape. |
| Reason: The steel rod from Korea is imported into the United States as straight lengths of steel. During the forming phase of the manufacturing process, the heated steel rods are coiled around a mandrel to specifications. The steel rod transforms from a straight length of steel into a spiral of successive coils capable of elastically expanding and contracting under force. A straight length of steel rod is incapable of functioning in this manner due to the absence of successive coils which form the identifiable and functional shape of a coil spring. During the manufacturing process in the United States, the steel rod is transformed into an article with a new name, character, and use than what was present prior. |
| Ruling Date: May 20, 2025 |
N348468: The tariff classification of aircraft 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 1 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 B757 and B767 aircraft. Part 2 is a “Stage 3” turbine nozzle casting. These castings will be further machined to make stage 3 turbine nozzles for gas turbines, which are installed in Boeing B757 and B767 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. Both turbine nozzle castings are made of a Nickel-base alloy, commercially known as “Mar-M247” and “INCO 713LC.” |
| Reason: N/A |
| Ruling Date: May 20, 2025 |
N348499: The tariff classification of a cold plate from China
| HTS: 8507.90.8000, 9903.01.24; 9903.94.05; 9903.01.33; 9903.88.01, 3.4% + 20% + 25% + 25%, “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Parts: Other.” |
| Item: The merchandise under consideration is an aluminum cold plate, and is described as a rectangular microchannel plate with manifolds. Coolant enters the first manifold, flows through coolant channels in the microchannel plate, and exits via a second manifold. The cold plate is installed directly against battery modules inside the XRANGE lithium-ion battery pack (a battery assembly used in an electric vehicle) and connected to a circulating coolant circuit in the vehicle. As the coolant flows through the cold plate, it removes thermal energy and carries it away from the battery assembly. While referred to as a “cold plate,” it can also be used to warm a battery module by circulating a heated transfer medium. |
| Reason: N/A |
| Ruling Date: May 20, 2025 |
N348521: The tariff classification of a motor home from France
| HTS: 8703.33.0130, 9903.01.25, 2.5% + 10%, “Motor cars and other motor vehicles principally designed for the transport of persons….: Other vehicles, with only compression-ignition internal combustion piston engine (diesel or semi-diesel): Of a cylinder capacity exceeding 2,500 cc.: Motor Homes.” |
| Item: The item under consideration has been identified as a 1997 Renault Midliner M210 4x4 cab-chassis with a permanent RV habitat. The vehicle is powered by a 6.18 Liters (6,180 CC) diesel engine. The vehicle’s habitation unit is permanently mounted by mechanical bolts and is not designed to be removed or be used separately from the vehicle as a standalone unit. The vehicle originally served as a French Fire Truck until 2020. The motor home is designed to carry a family of up to six (6) individuals, and provides a permanently mounted area to sleep, cook, bath, and seek shelter from inclement weather. |
| Reason: N/A |
| Ruling Date: May 20, 2025 |
N348625: The tariff classification of a sensor module from Japan
| HTS: 9031.80.8085, 9903.01.25, free + 10%, “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” |
| Item: The item under consideration is described as the 5Q-SSM sensor module, which is a Quartz Crystal Microbalance (QCM)-type smell sensor that detects changes in mass due to the adsorption/desorption of odor molecules onto a membrane surface. These changes are translated into resonance frequency shifts (in Hz) of the quartz crystal unit and output as digital data. The sensor can be embedded into other articles or used as a standalone device. The 5Q-SSM measures 20mm by 28mm by 2.84mm and weighs 10g. It is imported with the sensor (including 5 membranes with different chemical affinity), a USB converter board, an optional protective case, a USB flash drive with software, and a micro-USB cable. The sensor module includes a set of five standardized membranes designed for general odor identification (such as ethanol, toluene, kerosene, etc.). |
| Reason: N/A |
| Ruling Date: May 20, 2025 |
N348691: The tariff classification of a CV Joint assembly and outboard boot from South Korea
| HTS: 8708.99.6890, 9903.94.05; 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicle of headings 8701 to 8705: Other: Other parts for power trains: Other” |
| Item: The first item under consideration is identified as a Constant Velocity (CV) Joint Assembly, which is a component that connects from the drive shaft or axle to the wheel hub. The purpose of this component is to transmit torque to the wheel allowing the wheel to rotate at a constant speed even when the vehicle is turning or sharp turns caused by steering and during suspension movements. The CV Joint assembly ensures power is transferred smoothly and efficiently from the transmission to the wheels. The second item under consideration is identified as an Outboard Boot, which is a flexible thermoplastic cover that encases the CV joint assembly protecting it from dirt, moisture, and debris while retaining the lubricating grease inside. It serves as a protective barrier for the CV Joint assembly, preventing contaminants that could cause premature wear or mechanical failure. |
| Reason: N/A |
| Ruling Date: May 20, 2025 |
N348699: The tariff classification of desand tank module 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 341 Desand Tank Module (341 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 341 Module will be installed downstream from the Seawater Treatment Plant which provides seawater injection to subsurface reservoirs in the NPF. The 341 Module employs a gravitational separation process to separate solids and sediments from four upstream input flows. Desand slurry flowing into the 341 Module is a mixture of water and sand, and small amounts of entrained oil. |
| Reason: N/A |
| Ruling Date: May 20, 2025 |