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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N348805: The country of origin of exam gowns and capes
| Origin: China |
| Item: The products under consideration are paper medical exam gowns and capes. The capes and gowns are cut to shape with curved neck, shoulders, and underarms, folded at the underarms, glued at the shoulders, and have a full opening that can be turned to the front or back of the garment. The gown also comes with a 5/8”-wide plastic strip which functions as a belt. Both are made from multi-ply paper and are non-sterile. The master rolls of paper originate in Indonesia. The paper is then shipped to China, where it is cut to shape, folded at the underarms, and glued at the shoulder seams. The gowns and capes are then folded and packaged for sale. |
| Reason: In China, the paper is cut to shape, the garments are folded, and the shoulder seams are glued. The totality of these operations constitutes a substantial transformation. Sheet paper is transformed into a functional, disposable garment. Therefore, China is the country of origin of the capes and the gowns. |
| Ruling Date: May 30, 2025 |
N348855: The tariff classification of data loggers from China
| HTS: 9031.80.8085, 9903.01.24; 9903.01.25; 9903.88.01, free + 20% + 10% + 25%, “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 first item under consideration is the Multi-Use RLT V55 Plus, which is a reusable real-time data logger with global 4G/5G LTE connectivity. It uses embedded cellular modems and SIM cards to connect autonomously to the internet and transmit collected data. The data logger automatically transmits all data to the CSafe Connect cloud platform via cellular networks. The second item under consideration is described as the Single-Use RLT V5J Plus, which is a single-use version of the Multi-Use RLT V55 Plus. The third item under consideration is described as the TracSafe RLT t72 PRO.1 Meter Probe, which is a real-time wireless transmission device featuring 4G/5G LTE cellular connectivity. All three devices allow users to verify ambient temperature using the internal device, external temperature using the probe routed into the package or crate, humidity, shock, light, tilt and GPS location. |
| Reason: N/A |
| Ruling Date: May 30, 2025 |
N348856: The tariff classification of data loggers from China
| HTS: (TracSafePRO and TracSafe NFC Label) 9025.19.8085, 9903.01.24; 9903.01.25, 9903.88.01, free + 20% + 10% + 25%, “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: Thermometers and pyrometers, not combined with other instruments: Other: Other: Other: Other.”(TracSafeMAX and TracSafeMAX) 9031.80.8085, 9903.01.24; 9903.01.25, 9903.88.02, free + 20% + 10% + 25%: “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 first item under consideration is described as the TracSafePRO, which is a single-use data logger designed to capture temperature and light. The device is read by plugging in the USB connector on the side of the unit to a computer. The device also has an LCD screen to display the results, a power button, an LED indicator, and a light sensor. The second item under consideration is described as the TracSafeMAX, which is a reusable, Bluetooth-enabled data logger that connects directly to a smart device. Additionally, the user can plug the device into the USB port of a computer to download the recorded data. The device allows users to verify payload and ambient temperature, humidity, light and shock events. The third item under consideration is described as the TracSafeMAX – Probe, which is a reusable, Bluetooth-enabled data logger that connects directly to a smart device. Additionally, the user can plug the device into the USB port of a computer to download the recorded data. This device is nearly identical to the second item but also includes an additional temperature sensor probe. The fourth item under consideration is described as the TracSafe NFC Label, which is a compact, near field communication (NFC)-enabled smart tag with built-in environmental sensor. When a user scans the label with an NFC-capable mobile device, data is transferred wirelessly to the TracSafe app. |
| Reason: N/A |
| Ruling Date: May 30, 2025 |
N348905: The country of origin of a scissor jack
| Origin: Thailand |
| Item: The merchandise under consideration is identified as a scissor jack, and is described as a screw-operated jack for lifting vehicles. It uses a hand crank assembly to convert rotational motion into linear motion. The crank drives a screw which causes the scissor arms to move closer together and raise a vehicle. The subject scissor lift is manufactured in Thailand using materials and components sourced from Thailand and China. A bearing, a handle assembly, and pins are sourced from China. The remaining components are produced in Thailand from steel bar, steel plate, and steel tubing. These include an upper arm assembly, lower arm assembly, base, screw rod, and more. |
| Reason: Nearly all the components, including the upper assembly, lower assembly, screw rod, and more, are manufactured in Thailand. After processing, these critical components of the scissor jack emerge with a new name, character, and use, different from that possessed by the materials (e.g., steel tube, steel bars, and steel sheets) from which they were formed. Thus, based on the totality of the circumstances, the country of origin of the scissor jack will be Thailand. |
| Ruling Date: May 30, 2025 |
N348957: The tariff classification of earrings from China
| HTS: 7116.20.0500, 9903.01.24; 9903.01.25, 3.3% + 20% + 10%, “Articles of natural or cultured pearls, precious or semi-precious stones (natural, synthetic or reconstructed): Of precious or semiprecious stones (natural, synthetic or reconstructed): Articles of jewelry: valued not over $40 per piece: other.” |
| Item: The articles at issue are earrings composed of steel. They have disk clutch backs with 1.5mm cubic zirconia. The cost per set is $1.45. |
| Reason: N/A |
| Ruling Date: May 30, 2025 |
N349038: The country of origin of a digital stick thermometer
| Origin: China |
| Item: The item under consideration is described as a digital human body temperature thermometer, which is a digital stick thermometer that provides the temperature reading to the user via an integrated backlit LED screen. In operation, the user will place the thermometer in the mouth, rectum, or under the armpit and wait for the reading to display. To manufacture the digital human body temperature thermometer components are gathered from China and Cambodia. The Chinese components include the MT movement, LCD screen, MT sheath, buzzer, conductive shrapnel, conductive bar, conductive point, Chip-on-Board (COB), sensor, battery and battery clamps. The Cambodian components include the label, giftbox, manual, inner box, carton box, enclosure, cover and dustproof case. The complete assembly is performed in Cambodia. |
| Reason: The Chinese-produced components provide the essence of the digital thermometer. The Chinese components, including the COB and sensor, are not substantially changed by the assembly operations performed in Cambodia, as these operations are not complex or meaningful enough and they do not render a new and different article. The Chinese-produced components contain the “enabling technology” that provides the essential operation elements for the digital stick thermometers to work. In view of these facts, the country of origin is China. |
| Ruling Date: May 30, 2025 |
N349047: The tariff classification and country of origin of a seat
| HTS: 9401.39.0010, 9903.01.25, free + 10%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Swivel seats with variable height adjustment: Other: Household.” |
| Origin: Vietnam |
| Item: The “Torval Executive Big & Tall Chair (black),” is a manual gas lift, variable height adjustment, swivel seat that is constructed of injection molded plastic, wood, and a metal frame. The upholstered seat has a swivel mechanism, five wheeled casters, and padded armrests. The seat backrest and the seat foundation textile fabric are constructed of polyurethane artificial leather. The seat incorporates a cable control and butterfly seat plate that allows the seat to recline. Seating is provided for a single individual. An operation wherein the textile components (bonded leather + PVC textile fabric), plastic components (casters) and the metal components (headrest adjuster, seat plate, gas lift, assembly hardware) will be sourced in China. The seating components will be shipped and exported to Vietnam. In Vietnam, plastic components (armrests, swivel base), wood components (plywood), metal components (pocket coil spring), polyurethane foam, thread, glue, staples, labels, plastic bags, cardboard, and packing materials will be locally sourced. In Vietnam, the incomplete, unassembled, and unfinished seating components will undergo manufacture. |
| Reason: The Chinese components lose their identity during manufacture and undergo a substantial transformation in Vietnam to become a complete and unassembled seat, thereby, taking on a new name, character, and use. Furthermore, the manufacturing operations performed in Vietnam constitute more than minor processing and exceed simple assembly. In view of these facts, the country of origin for the seat will be Vietnam. |
| Ruling Date: May 30, 2025 |
N349118: The tariff classification of a ventilator filter from China
| HTS: 8421.39.0115, 9903.01.24; 9903.01.25; 9903.88.01, free + 20% + 10% + 25%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for gases: Other: Dust collection and air purification equipment: Other.” |
| Item: The item under consideration is described as the AVEA filter, which is a disposable bacterial/viral filter designed for use with the AVEA ventilator system. The AVEA ventilator system is a critical care ventilator intended to provide continuous mechanical ventilation support to neonatal, pediatric, and adult patients who require invasive or non-invasive ventilatory assistance. This filter is placed in-line with the patient circuit, typically at the expiratory limb or between the ventilator and the patient interface, to protect the internal components of the ventilator from contamination by exhaled air. The filter also prevents cross-contamination between patients and helps maintain the hygiene and operational integrity of the ventilator system. The HEPA filtration element is a single-use and disposable filter that arrives in an individually wrapped sterile package. |
| Reason: N/A |
| Ruling Date: May 30, 2025 |
N349303: The tariff classification of integrated circuit sockets from Japan
| HTS: 9030.82.0000, 9903.01.25, free + 10%, “Oscilloscopes, spectrum analyzers and other instruments and apparatus for measuring or checking electrical quantities, excluding meters of heading 9028; instruments and apparatus for measuring or detecting alpha, beta, gamma, X-ray, cosmic or other ionizing radiations; parts and accessories thereof: Other instruments and apparatus: For measuring or checking semiconductor wafers or devices (including integrated circuits).” |
| Item: The items under consideration are described as integrated circuit (IC) sockets, which are devices used for testing semiconductor chips during the semiconductor manufacturing processes. These sockets are mounted onto a burn-in board (BIB), or test board, during quality control and reliability assessments. The BIB is connected to a pattern generator and power supply in the burn-in chamber. The chamber that surrounds the burn-in board provides an environment for testing the chips under a range of temperatures (from -60°C to 150°C). The sockets ensure secure electrical contact with the device under test and allow repeated insertions without causing damage to the chip. The IC sockets are used solely in the semiconductor testing environment and are primarily used for testing applications in consumer electronics, automotive, and industrial integrated circuits. |
| Reason: N/A |
| Ruling Date: May 30, 2025 |
N349427: The tariff classification of Halloween decorations from China
| HTS: 9505.90.6000, 9903.01.24; 9903.01.25, free + 20% + 10%, “Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Other: Other.” |
| Item: The Halloween Mickey and Minnie Jack-O-Lantern Night Light, which consists of an assortment of two styles of battery-powered, illuminated, plastic decorations with timers. One style depicts the classic Mickey Mouse head as a jack-o’-lantern with a stem on top and two pumpkins for ears. The other style depicts Minnie Mouse, which is the same as the Mickey Mouse head style but has a large bow on top instead of a stem. The items are marketed and sold separately for Halloween. |
| Reason: N/A |
| Ruling Date: May 30, 2025 |