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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N349467: The tariff classification of a card holder from China
| HTS: 4202.31.6000, 9903.91.03, 9903.01.24, 9903.01.25, 8% + 20% + 10% + 25%, “articles of a kind normally carried in the pocket or in the handbag, with outer surface of leather or of composition leather, other.” |
| Item: The article at issue is a card holder. It is constructed from a rigid polycarbonate frame, wrapped in bovine leather, and is designed to hold up to three standard-sized cards (e.g., credit cards, ID cards). The product also incorporates an embedded magnetic array, which aligns with Apple’s MagSafe system, allowing the item to attach magnetically to compatible iPhone models. |
| Reason: N/A |
| Ruling Date: June 23, 2025 |
N349599: The tariff classification of an air vent grill from South Korea
| HTS: 8708.29.5160, 9903.94.05; 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.” |
| Item: The article under consideration is an Air Vent Grill, which is used in passenger vehicles. The air vent grill is a plastic injection-molded product assembled into the vehicle ceiling and measures 118mm x 118mm x 26mm. It functions as a vent for the heater or air conditioner, allowing manual opening/closing and adjustment of the airflow direction. |
| Reason: N/A |
| Ruling Date: June 23, 2025 |
N349638: The tariff classification of a Watercolor Painting Kit and a Book Stenciling Kit from China
| HTS: 3213.10.0000, 9903.01.24; 9903.01.63; 9903.88.03, 6.5% + 20% + 10% + 25%, “Artists’, students’ or signboard painters’ colors, modifying tints, amusement colors and the like, in tablets, tubes, jars, bottles, pans or in similar forms or packings: Colors in sets.” |
| Item: The Watercolor Painting Kit will be used to learn how to paint with watercolors. The kit includes a 48-page instructional paperback book, 6 tubes of watercolor paints in assorted colors, 5 sheets of 300 GSM paper, 4 paint brushes in assorted sizes, 2 metallic watercolor paint squares, 1 paint palette, and 1 white gel pen. All of the kit’s components are packaged together in a manner suitable for sale directly to users without re-packing. The Book Stenciling Kit will be used to personalize books by applying designs to the exposed edges of the pages. This kit includes a 24-page project book, 6 specialty paint pods in assorted colors, 6 acrylic paint pods in assorted colors, 6 stencils, 3 sponge sticks, 2 clamps, 1 white paint pen, and 1 gold metallic marker. All of the kit’s components are packaged together in a manner suitable for sale directly to users without re-packing. |
| Reason: The Watercolor Painting Kit and Book Stenciling Kit will be classified as sets for tariff classification purposes in accordance with GRI 3(b), with the essential character imparted by the paints, paint brushes, sponge sticks, and paint palette (colors in sets), based on their role in relation to the product’s use. |
| Ruling Date: June 23, 2025 |
N349761: The tariff classification of a wafer polishing mounting jig from Japan
| HTS: 8486.90.0000, 9903.01.32, free, “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in Note 11(C) to this chapter; parts and accessories: Parts and accessories.” |
| Item: The mounting jig is a flat, round, 1.35mm thick article with a 454mm outer diameter, and is used in Chemical Mechanical Polishing (CMP) machines suitable only for semiconductor wafer polishing applications. The mounting jig can hold up to five silicon carbide (SiC) semiconductor wafers. The mounting jig is composed of four layers: a frame layer of polyetherimide resin, a surface layer of polyethylene foam, a bonding layer of rubber adhesive and polyethylene terephthalate film (film), and an adhesive layer of acrylic adhesive, film, and cellulose release paper. Each of the mounting jig’s five round holes (openings) holds a single wafer for polishing. The wafers are held in place only by the shape of the jig. The mounting jig is attached to the CMP polishing machine by adhesive tape at the bottom of the jig, securing the two together. The mounting jig is specifically shaped and designed to fit the CMP equipment of the customer’s specific machine. |
| Reason: N/A |
| Ruling Date: June 23, 2025 |
N349781: The tariff classification of film transport gripper chain from Germany
| HTS: 7315.11.0060, 9903.81.90; 9903.01.33, free + 50%, “Chain and parts thereof, of iron or steel: Articulated link chain and parts thereof: Roller chain: Other: Other.” |
| Item: The product under consideration is identified as film transport gripper chain for use in packaging machines. The steel roller chain consists of springs and gripper clamps that hold the plastic film in place that will form and seal the packages which are produced on the packaging machine. |
| Reason: N/A |
| Ruling Date: June 23, 2025 |
N349884: The tariff classification of gloves from Pakistan
| HTS: 4203.29.5000, 9903.01.25, 12.6% + 10%, “Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Other: Other: Other: For other persons: Lined.” |
| Item: A unisex work glove with a palm side from fingertips to wrist and fourchettes constructed of goat leather. The back side is constructed of a knit textile fabric. The glove features foam padding patches on the underside, an elasticized wrist, polyvinyl chloride knuckle protection, overlays on the back side fingertips and a layer of knit textile fabric lining the underside. |
| Reason: The essential character of the glove is imparted by the goat leather palm side. |
| Ruling Date: June 23, 2025 |
N349887: The tariff classification of a coin purse with charms from Indonesia
| HTS: 4202.32.1000, 9903.01.25, 12.1¢/kg + 4.6% + 10%, “articles of a kind normally carried in the pocket or the handbag, with outer surface of sheeting of plastic or of textile materials, with outer surface of sheeting of plastics, of reinforced or laminated plastics.” |
| Item: The subject merchandise is composed of a coin purse and three detachable charms. The purse is constructed with an outer surface of plastic sheeting and measures approximately 4.5” (W) x 1.5 (D) x 3.25” (H). The purse will be set up for retail sale with the three charms which will be used to personalize and decorate it. The purse and charms are considered a set for tariff purposes, General Rule of Interpretation 3(b) noted. |
| Reason: The essential character is imparted by the purse as it is fully functional with or without the charms, which are merely optional components. Moreover, while the charms may compel the consumer to choose this purse over others, it is the useful functions of the purse which will motivate the consumer to purchase it. |
| Ruling Date: June 23, 2025 |
N349945: The tariff classification of a costume from China and Vietnam.
| 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: A toddler-size costume identified as Sweet Pilgrim, which consists of a long-sleeved pullover dress with an attached apron and a bonnet, and features a single ply flat collar with raw unfinished edges, the neck also has a deep back opening with raw, unfinished edges, closed by a single tab of hook and loop fastener. The attached apron and ties are raw and unfinished. The flimsy half elastic waist consists of a strip of narrow exposed elastic stitched directly to the back waist of the dress with one row of long, loose straight stitching. The long sleeves end in a folded band. The hem bottom is raw and unfinished. Although there is some capping on top of the flimsy collar, the dress is not well-made. The dress is stitched together with long, loose, straight stitching. |
| Reason: The flimsy man-made knitted textile dress provides the essential character of the set. |
| Ruling Date: June 23, 2025 |
N350041: The country of origin of a glucose monitoring device
| Origin: Malaysia |
| Item: The item under consideration is described as the Atlas CGM Reader, which is a continuous glucose monitoring device for patients with diabetes mellitus. It is a compact, handheld device used in conjunction with Abbott’s FreeStyle Libre sensor to help people with diabetes monitor their glucose levels. With regard to the origin of the Reader, all of the research and development, product engineering, hardware design, product software development, and other design investment for the CGM Reader occur in the United States. In total, the CGM Reader comprises 228 parts, the majority of which make up the printed circuit board assembly. 41% of the parts by value are from China (including the liquid crystal display, battery, bare PCB, and vibration motor as the most expensive components); 10% from Taiwan (flash memory); 5% from Thailand (transceiver); 4% from Singapore (plastic components); 3% from Japan; 2% from Vietnam; 1% each for the Philippines, Korea and Malaysia; and the remaining 32% (primarily capacitors, resistors, inductors, diodes and other electronic components) being dual-sourced from two or more of the above-mentioned countries. The manufacturing of the CGM Reader occurs in six stations. |
| Reason: The assembly of the PCBA in Malaysia by soldering the individual components of various origins onto a bare printed circuit board results in a substantial transformation of those components to produce a PCBA of Malaysian origin. The addition of the remaining components in Malaysia largely completes the production of the finished reader, albeit without the final configurations, and allows it to be used for no other purpose than as a glucose meter. While the final configuration is completed in Singapore, the device is substantially transformed from the product leaving Malaysia. As a result of the foregoing, we find that the Atlas CGM Reader is considered a product of Malaysia. |
| Ruling Date: June 23, 2025 |
N349448: The tariff classification of composite frames for photovoltaic (PV) solar panels from China
| HTS: 8541.90.0000, 9903.01.24, 9903.01.32, 9903.91.05, free + 20% + 50%, “Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED), whether or not assembled with other light-emitting diodes (LED); mounted piezo-electric crystals; parts thereof.” |
| Item: The items concerned are composite structural frames used in the manufacture/assembly of photovoltaic (PV) solar panels. These particular frames are produced using a pultrusion process that combines continuous glass fibers and polyurethane resin to form lightweight yet rigid profiles (fiber-reinforced polymer composite frames). The composite frames serve the same functional purpose as traditional aluminum frames, as they encase or frame the bare outer edge of the laminated solar panel, providing support and rigidity. They form an integral part of the finished solar panel/module. |
| Reason: N/A |
| Ruling Date: June 10, 2025 |