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.
N349032: The tariff classification of a vehicle control unit from Korea
| HTS: 8543.70.9860, 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: Other: Other: Other: Other.” |
| Item: The merchandise under consideration is identified as two models of the Advanced Driver Assistance System (ADAS) Park Electronic Control Unit (ECU), which are virtually identical and function the same with the only difference being the shape of the bracket that is attached and used to mount the device within a vehicle. The subject device comprises a Printed Circuit Board Assembly (PCBA), which contains a microcontroller, vision processor, various transceivers, as well as other electrical components. This PCBA is housed within a plastic enclosure and incorporates a cooling fan assembly. As noted above, a metal bracket for installation is on the outside of the housing. |
| Reason: N/A |
| Ruling Date: May 23, 2025 |
N348147: The country of origin of ignition coils for an automotive engine
| Origin: Thailand |
| Item: The ignition coils are fully produced and assembled in Thailand. The raw materials are either of Chinese or Thai origin. All production work is done in Thailand. Ignition coils are a crucial component in a vehicle's ignition system. Its primary function is to convert the low voltage from the car's battery into the high voltage needed to create a spark in the spark plugs. This spark ignites the air-fuel mixture in the engine cylinders, enabling the engine to run. |
| Reason: The Ignition Coil’s components and subassemblies are substantially transformed during the manufacturing process in Thailand. Thus, the country of origin of the complete automotive engine Ignition Coil is Thailand for marking purposes. |
| Ruling Date: May 22, 2025 |
N348398: Country of origin determination for automobile mats; 19 CFR 102.21(c)(2); tariff shift
| Origin: Thailand |
| Item: The subject merchandise consists of a set of four automobile floor mats, which are of woven polyester backed with polyvinyl chloride (PVC). The mats are finished with knit polypropylene binding around the edges. The driver’s side floor mat includes a sewn on PVC heel pad. The mats are available in multiple colors, including black, beige and gray. The manufacturing operations for the automobile mats are as follows: In China, polyester yarn is spun. Polyester yarn exported to Thailand. In Japan, PVC particles are made. PVC particles are exported to Thailand. In Thailand, polyester carpet fabric is woven. Polypropylene binding is knit. PVC particles are processed. PVC particles are injected to form heel pad. Carpet backing is laminated with PVC. Laminated carpet is cut to size and shape. Heel pad is sewn onto face of driver’s side floor mat. Binding is sewn around the edge of the floor mats. Floor mats are packaged and exported to the United States. |
| Reason: As all of the foreign materials incorporated in the floor mats undergo an applicable change in tariff classification in a single country, that is, Thailand, as per the terms of the tariff shift requirement, country of origin is conferred in Thailand. |
| Ruling Date: May 22, 2025 |
N348508: The tariff classification of a metrology and inspection machine from Israel
| HTS: 9031.41.0040, 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 optical instruments and appliances: For inspecting semiconductor wafers or devices (including integrated circuits) or for inspecting photomasks or reticles used in manufacturing semiconductor devices (including integrated circuits): For inspecting semiconductor wafers or devices: For wafers.” |
| Item: The item under consideration is described as the Eagle metrology and inspection machine, which is a device designed for two-dimensional (2D) and three-dimensional (3D) Automatic Optical Inspection (AOI). The Eagle provides comprehensive coverage for semiconductor manufacturing, supporting front-side inspection at sub-micron defect levels, as well as backside and edge inspection. The 3D metrology solution delivers precise measurements for micro-bump coplanarity and height, handling up to 500 million bumps per wafer. The machine is specifically designed to inspect integrated circuits (wafers and chips) and measures features and defects on silicon wafers throughout the manufacturing process of semiconductor devices. The inspection covers the front and mid-end and up to the beginning of the assembly process (packaging and post-dicing). |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348390: The tariff classification of a valve body assembly and a valve body frame from Mexico
| HTS: (valve body assembly) 8481.20.0050, 9903.01.27, 9903.01.01, 2% + 25%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Valves for oleohydraulic or pneumatic transmissions: Hydraulic valves: Other.” (valve body frame) 8481.90.9020, 9903.01.27, 9903.01.01, free + 25%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Of valves of subheading 8481.20: Valve bodies.” |
| Item: The first item at issue is referred to as a valve body assembly, which is a valve comprised of layered aluminum alloy housings that feature precisely machined passages and components, such as various spool valves, check valves, pistons, springs and two separator plates. The solenoids that are intended to be incorporated with their respective valves are imported separately. The valve body assembly is used within the transmission system of a motor vehicle. The second item is referred to as a valve body frame, which is an aluminum alloy housing that features precisely machined passages and inserts specifically designed to incorporate separately imported springs, pistons and valves. The valves control the flow and direction of hydraulic fluid within a transmission system of a motor vehicle. |
| Reason: N/A |
| Ruling Date: May 21, 2025 |
N348487: The tariff classification of hydronic radiant cooling and heating systems from Canada
| HTS: (aluminum hydronic cooling and heating systems) 7616.99.5190, 9903.01.10, 9903.01.26, 2.5% + 25%, “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” (steel hydronic cooling and heating systems) 7322.19.0000, 9903.01.10, 9903.01.26, free + 25%, “Radiators for central heating, not electrically heated, and parts thereof, of iron or steel . . .: Radiators and parts thereof: Other.” |
| Item: The items under consideration are described as hydronic radiant cooling and heating systems that consist of ceiling or wall-mounted panels that heat or cool indoor spaces by circulating chilled or heated water through affixed tubing. The systems are integrated with and rely on a building’s central boiler, chiller, or heat pump system. During operation, the systems receive water and circulate it through a network of copper pipes affixed to aluminum or steel paneling. As the water circulates, heat is transferred to or from the panel surface. In turn, this affects the surrounding ambient temperature. Each panel primarily consists of formed aluminum or steel sheet which houses 5.8-inch outer diameter serpentine copper tubing. An aluminum sheet metal configuration features either 14-gauge perforated aluminum or 18-gauge unperforated aluminum. An alternative configuration is built with extruded aluminum clinched, screwed, or welded together to form a panel profile to specifications. |
| Reason: The totality of the metal components provides the structure for mounting, for securely holding them together, and for facilitating the flow of chilled or heated water during operation. Furthermore, the metal components provide the physical forms and surface areas that enable heating by infrared radiation and cooling from radiant absorption. In addition, the metal components provide convective cooling and heating effects. As a result, the metal components impart the essential character of the hydronic cooling and heating systems. Aluminum predominates by weight in the aluminum panel models, and steel predominates by weight in the steel panel models. |
| Ruling Date: May 21, 2025 |
N348514: The country of origin of an engine crane
| Origin: Thailand |
| Item: The merchandise under consideration is identified as an engine crane, which is a crane for raising and lowering a vehicle engine. It is not self-propelled and has a metal frame with foldable legs and an extendable boom. A non-motorized power unit allows an operator to raise and lower the engine. The subject engine crane is produced in Thailand using materials and components sourced from China and Thailand. It will be imported as individual parts in retail packaging for the end user to assemble. The unassembled parts are broken down into a power unit, structural components, and other parts. The power unit and all structural components are produced in Thailand. The main subcomponents of the power unit include a base, outer sleeve, cylinder, base connection, pump body, piston rod, and piston cap. Each of these subcomponents is created in Thailand. |
| Reason: The dominant components, including the power unit and all the structural components, are manufactured in Thailand. After processing, these critical components of the engine crane emerge with a new name, character, and use, different from that possessed by the materials (e.g., steel pipes, steel bars, steel sheets, steel flats, etc.) from which they were formed. Thus, based on the totality of the circumstances, the country of origin of the engine crane will be Thailand. |
| Ruling Date: May 21, 2025 |
N348569: Country of origin determination for a throw
| Origin: China and Vietnam |
| Item: The subject merchandise consists of a plush faux fur throw composed of two layers: a 100% polyester knit plush fleece fabric on the face side featuring a printed multi-colored plaid design and a dyed 100% polyester knit long faux fur pile fabric on the bottom side. The blanket is sewn along the edges with a knife edge finish. The manufacturing operations for the throw are as follows: Scenario 1, in China, knitted greige plush fleece face fabric is formed. Knitted faux fur fabric is formed. Knitted faux fur fabric is dyed and brushed. Both fabrics are shipped in rolls to Vietnam. In Vietnam, the knitted greige plush fleece fabric is printed with a plaid design and brushed. The plaid plush fleece and faux fur knitted fabrics are cut and assembled by sewing into a finished throw. The finished product is packaged and shipped to United States. Scenario 2: In China, Polyester yarns for plush fleece fabric are formed. Knitted faux fur fabric is formed. Knitted faux fur fabric is dyed and brushed. Yarns and knitted faux fur fabric are shipped to Vietnam. In Vietnam, knitted greige plush fleece face fabric is formed. Greige plush fleece fabric is printed with a plaid design and brushed. The plaid plush fleece and faux fur knitted fabrics are cut and assembled by sewing into a finished throw. The finished product is packaged and shipped to United States. |
| Reason: In scenario 1, as the fabrics are formed in a single country, that is, China, as per the terms of the tariff shift requirement, the country of origin of the plush faux fur throw is China. Under scenario 2, the country of origin of the subject plush faux fur throw is conferred in the last country in which an important assembly or manufacturing process occurred, that is, Vietnam. |
| Ruling Date: May 21, 2025 |
N348624: The tariff classification of steel separator discs from Taiwan
| HTS: 8466.94.8585, 9903.01.25, 4.7% + 10%, “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465…: Other: For machines of heading 8462 or 8463: Other: Other: Other.” |
| Item: The items under consideration are described as steel separator discs for use on the overarm separator shaft of a slitting line. After wide coils of metal are slit into narrower strips, the separator discs ensure neat and uniform rewinding onto the recoiler component of a slitting line. The separator discs are made of hardened steel and may be precision-ground or coated to prevent the marking or scratching of high-finish workpieces. |
| Reason: N/A |
| Ruling Date: May 21, 2025 |
N348743: The country of origin of fiber optic terminal boxes
| Origin: U.S. |
| Item: The merchandise under consideration is described as five versions of a fiber optic terminal box, which consist of a fiber optic splitter assembly, comprising a single fiber optic core split into multiple connection points, enclosed within a waterproof plastic box. The terminal boxes are used to provide fiber optic network connection within a commercial or private installation. The manufacturing for all five models is the same and is completed in China. This process begins with the creation of the splitter assembly. U.S. originating optical fiber is imported into China on reels and then cut to length and jacketed with Chinese PVC. A splitter module is then assembled onto the fiber, splitting the fiber into multiple outputs. A connector is then assembled and glued onto the end of each output. This creates the finished splitter assembly. The splitter assembly is then assembled within the molded plastic box of Chinese-origin by clipping in the connectors and coiling the cable within. Various other smaller components are then added including holders, adapters, and cartridges. The finished terminal box is then packaged for shipment to the United States. |
| Reason: The splitter assembly, manufactured with U.S. optical fibers, imparts the character of the finished device. Further, the US originating optical fiber is the essential functional component of not just the splitter, but the finished terminal box. The assembly process performed in China is not significantly complex to transform the US components into a new and different article of commerce. As such, based on the facts presented, the origin of the fiber optic terminal boxes, is the U.S. |
| Ruling Date: May 21, 2025 |