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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N349457: The tariff classification of a steel structure from Colombia
| HTS: 7308.90.9590, 9903.81.90, 9903.01.33, free + 25%, “Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The product under consideration is identified as a steel structure for an automated storage system. The steel structure is composed of pallet racking frames, main aisle beams, inner beams, and steel grating. All components are shipped together unassembled and ready for installation after importation into the United States. |
| Reason: N/A |
| Ruling Date: May 30, 2025 |
N348721: The tariff classification and country of origin of a seat component
| HTS: 9401.99.1085, 9903.01.24; 9903.01.25; 9903.88.15, free + 20% + 10% + 7.5%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of seats of a kind used for motor vehicles: Other.” |
| Origin: China |
| Item: The “HDM-Horizontal Driving Mechanism (HDM)” is a seat component constructed of metal and plastic that will be permanently affixed to the metal frame of a motor vehicle seat. The assembly contains no upholstery, no cushions, no seat foundation, backrest, legs, or armrests. The metal components (leadscrews, floating nuts, floating nut supports, lear nut supports, stop disks, metal worms) and the plastic components (nylon gears and damping materials) will be sourced in China. The seating components will be shipped to Thailand and no additional materials will be locally sourced. In Thailand, the metal and plastic components will be cleaned, inspected, assembled, measured, oiled, adjusted, tested, and laser marked. The seating components will then be packed, labeled, and exported to the United States. |
| Reason: The operations that will occur in Thailand consists primarily of assembly and do not change the basic nature of the article; it represents different stages of the same product. The assembly operations that will occur in Thailand do not result in a substantial transformation of a product having a new name, character or use. In view of these facts, the country of origin for the HDM will be China. |
| Ruling Date: May 29, 2025 |
N348812: The tariff classification and country of origin of wheel hub assemblies
| HTS: 8708.99.8180, 9903.01.25, 2.5% + 10%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” |
| Origin: Vietnam |
| Item: The items under consideration are 2nd Generation wheel hub assemblies containing ball or tapered roller bearings which are used in passenger vehicles. The assemblies consist of an outer flange, inner rings, balls or rollers, cages, magnetic ring (ABS ring), and a seal ring. The outer flanges and inner rings are imported from China and machined in Vietnam. The flanges are imported from China in an unfinished state and then fully processed by multiple precision turning operations, drilling or tapping, grinding, and super-finishing, to create a finished product. The inner rings also are fully processed from an unfinished state through multiple grinding, super-finishing, and other manufacturing processes to produce the precision raceways. The balls, rollers, cages, seals, and ABS rings are all made in China and imported to Vietnam for inspection and final assembly. In Vietnam, the components are assembled together using ball automatic assembly machines and hydraulic presses. After that, the wheel hub assemblies are inspected, laser marked, rust-proofed, tested, and packaged for shipment. |
| Reason: Although the wheel hub assemblies in the instant scenario are not mere bearings, their function is to reduce friction and to allow the wheel to be mounted on the axle. Since the outer flange and inner ring become races with precision raceways in Vietnam and drilling of the bolt holes also occurs in Vietnam, the country of origin of the wheel hub assemblies will also be Vietnam for marking purposes. |
| Ruling Date: May 29, 2025 |
N348978: The tariff classification of a jack stand from Vietnam
| HTS: 7326.90.8688, 9903.81.90; 9903.01.33, 2.9% + 25% + 10%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The item under consideration is described as a powder coated steel jack stand which supports the weight of a vehicle after it is lifted by another device. During use, the user adjusts the height of the jack stand’s ratchet stem to meet the chassis of a raised vehicle. |
| Reason: N/A |
| Ruling Date: May 28, 2025 |
N349318: The country of origin of shovels
| Origin: Vietnam |
| Item: The shovels comprise steel heads attached to a wood and fiberglass handle with a plastic grip. The manufacturing process begins in Vietnam, where Chinese-origin cold-rolled steel is cut into shovel head blanks. Each blank is then turned, heated, and formed into the final head shape of the shovel using a forming machine. The shovel heads are then sent to China where they are heat-treated, polished and powder coated. Chinese-origin wood and fiberglass handles are then attached and secured to the shovel heads, along with a plastic grip. |
| Reason: The cold-rolled steel is substantially transformed in Vietnam into fully formed shovel heads. It is the shovel head that imparts the essence of each finished shovel. The shovel heads are not substantially changed in China so as to transform them into a new article with a different name, character, or use. Additionally, the shovel heads are not substantially transformed by the attachment of a wood and fiberglass handle. The country of origin of the finished shovels is Vietnam. |
| Ruling Date: May 28, 2025 |
N348643: Classification and country of origin determination for surgical towels; 19 CFR 102.21(c)(2); tariff shift; De Minimis
| HTS: 6307.90.8910, 9903.01.25, 7% + 10%, “other made up articles, including dress patterns: other: other: surgical towels.” |
| Origin: Vietnam |
| Item: Blue operating room (OR) or surgical towels, used to wipe or to place under surgical instruments. The surgical towels are constructed from 100% cotton huck weave fabric. The towels are hemmed on all four sides, measure approximately 17 x 26 inches and feature a 100% cotton narrow woven fabric carrying loop sewn to the top right corner. The surgical towels feature either a data matrix tag (DMT) or Radio Frequency Identification (RFID) tag to assist with inventory management. The manufacturing operations for the surgical towels are as follows: In Vietnam, cotton yarns are formed. Cotton huck fabric is woven. Rolls of greige huck fabric are shipped to China. In China Loop fabric is woven. Cotton huck fabric is dyed. Cotton huck fabric is cut into rectangular shapes. Cotton huck cut fabric is hemmed along all four sides. A narrow woven carrying loop is sewn to the right top side edge. A DMT or RFID label is heat pressed to each towel. The towels are folded. The DMT or RFID labels are scanned and towels are banded together with a paper band. The finished surgical towels are packaged and shipped to the U.S. |
| Reason: The huck fabric is formed in Vietnam and the narrow woven loop fabric is formed in China; however, the narrow woven loop fabric is disregarded in accordance with Section 102.13, the De Minimis rule. Therefore, as the only fabric comprising the surgical towels to consider is formed in a single country, that is, Vietnam, as per the terms of the tariff shift requirement, country of origin is conferred in Vietnam. |
| Ruling Date: May 23, 2025 |
N348646: Classification and country of origin determination for a cushion cover; 19 CFR 102.21(c)(2); tariff shift
| HTS: 6304.93.0000, 9903.01.25, 9.3% + 10%, “Other furnishing articles, excluding those of heading 9404: Other: Not knitted or crocheted, of synthetic fibers.” |
| Origin: Taiwan |
| Item: A cushion cover made from 100%polyester, yarn-dyed, woven fabric. The cushion cover will be filled in the United States with 100% polyester batting. The cushion will be marketed as an outdoor patio cushion but is suitable for indoor use, as well. The manufacturing operations for the cushion cover are as follows: In Taiwan, polyester yarn is spun. Polyester fabric is woven. Polyester fabric is exported to China. In China, the zipper is manufactured. Polyester fabric is cut and assembled by sewing into completed cushion covers. Completed cushion covers are exported to the United States. |
| Reason: As the fabric for the cushion cover is formed in a single country, that is, Taiwan, as per the terms of the tariff shift requirement, country of origin is conferred in Taiwan. |
| Ruling Date: May 23, 2025 |
N348714: The tariff classification of couplings for hydraulic hoses from Mexico
| HTS: 8412.90.9015, 9903.01.01, 9903.01.27, free + 25%, “Other engines and motors, and parts thereof: Parts: Other: Of hydraulic power engines and motors: Other” |
| Item: The two items under consideration are described as couplings for hydraulic hoses, which are specifically designed for use with hydraulic systems, such as hydraulic power engines and motors. The couplings are used to connect hoses to other hydraulic components, such as pumps, cylinders, and valves. They allow for the efficient transfer of hydraulic fluid under extremely high pressure. The first item is identified as GlobalSpiral coupling, which is a steel, crimp design coupling for extremely high-pressure, high-impulse spiral-wire hydraulic hose applications and is capable of withstanding pressures up to 6,000 psi. The second item is identified as MegaCrimp coupling, which is a steel, crimp design, one-piece coupling with stem, pre-attached ferrule, and 37-degree flare seat with swivel lock nut. It is for use with extremely high-pressure, high-impulse spiral-wire hydraulic hose applications and is capable of withstanding pressures up to 6,000 psi. |
| Reason: N/A |
| Ruling Date: May 23, 2025 |
N348752: The tariff classification of a monitor from China
| HTS: 8528.52.0000, 9903.01.24; 9903.01.32, free + 20%, “Monitors and projectors not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other monitors: Capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471.” |
| Item: The merchandise under consideration is the AUO 17-inch LCD monitor, which is compatible with any device that has a VGA, DVI, HDMI, or Display Port. Additionally, this monitor is capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471. Moreover, it does not incorporate any television reception apparatus or a touchscreen. |
| Reason: N/A |
| Ruling Date: May 23, 2025 |
N348835: The tariff classification of a video production switcher from Canada
| HTS: 8543.70.9860, 9903.01.10, 9903.01.26, 2.6% + 25%, “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 the Kula Production Switcher and further described as a live video production device. The subject device is available with 1, 2, or 3 mix effect (M/E) banks with the capability to work in standard definition (SD), high definition (HD), 4k ultra-high definition (UHD), as well as various other video outputs. The subject switcher is composed of a main frame or enclosure, which houses the electronic components needed to process the video signals. On the exterior of the device is a panel with lighted keys, dials, sliders, and a joystick that can be configured in various M/E configurations, dependent on the needs of the operator. |
| Reason: N/A |
| Ruling Date: May 21, 2025 |