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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N350124: The tariff classification of Basic Yellow 40 from India
| HTS: 3204.13.1000, 9903.01.25, 6.5% + 10%, “Synthetic organic coloring matter, whether or not chemically defined; preparations as specified in note 3 to this chapter based on synthetic organic coloring matter; synthetic organic products of a kind used as fluorescent brightening agents or as luminophores, whether or not chemically defined: Synthetic organic coloring matter and preparations based thereon as specified in note 3 to this chapter: Basic dyes and preparations based thereon: Basic yellow 19, 23, 24, 25, 39, 40, 45, 54, 56, 63, 70, 77.” |
| Item: The subject product is identified as Basic Yellow 40 (CAS # 29556-33-0), with a chemical name of 2- [7- (diethylamino)-2-oxo-2H-1-benzopyran-3-yl]-1,3-dimethyl-1H-benzimidazolium chloride. Basic Yellow 40 is a bright greenish-yellow fine powder dye, which is soluble in water and alcohol. The dye will be imported in a quantity of 500 kilograms. This product’s uses include latent fingerprint enhancement after cyanoacrylate fuming, staining, and as a colorant in various applications. |
| Reason: N/A |
| Ruling Date: June 25, 2025 |
N350206: The tariff classification of a slide pad from the Czech Republic
| HTS: 8431.49.1090, 9903.01.25, free + 10%, “Parts suitable for use solely or principally with the machinery of headings 8425 to 8430: Of machinery of heading 8426, 8429 or 8430: Other: Of machinery of heading 8426: Other.” |
| Item: The merchandise under consideration is referred to as a slide pad, and is described as a hat-shaped circular disc made from a gear bronze alloy. It weighs 0.041 kilograms, has a diameter of 35 millimeters, and a height of 10 millimeters. The subject slide pad is installed in a Hiab HiPro 408 knuckle boom crane where it is used to reduce wear and friction between telescoping steel component sections as they slide past one another. |
| Reason: N/A |
| Ruling Date: June 25, 2025 |
N350212: The eligibility of the United States-Mexico-Canada Agreement (USMCA) of Gin from Canada
| USMCA Eligibility: Yes |
| Item: The subject merchandise is described as Empress 1908 Indigo Gin composed of spirits that contain neutral grain alcohol, juniper, coriander, grapefruit, and other botanicals. The Empress 1908 Indigo Gin is produced at a Canadian distillery from neutral grain alcohol of 192 proof (96% alc./vol.), of which 100% of the neutral grain alcohol originates in Canada. At the distillery, the neutral grain alcohol is macerated with botanicals that include juniper (product of Macedonia or Kosovo), coriander (India), grapefruit (Spain), cinnamon (Indonesia), ginger (India), and rose (Pakistan). The botanicals and alcohol are distilled to strip away impurities and create gin that is “full proof,” roughly 183 proof (91.7% alc./vol.), on average. The distilled product yields roughly 390 liters of absolute alcohol (LAA) from the initial volume of 480 LAA, or a recapture of 83% of the initial volume. This is said to remove impurities, such as light and heavy alcohol, and result in gin of suitable quality. The gin is then blended with Sensient Natural Blue (Italy) and water to create an 85 proof gin. The finished product is packaged in bottles of 375 ml, 750 ml, 1000 ml, and 1750 ml, labeled, boxed, and shipped to the United States. |
| Reason: No non-originating alcoholic ingredients are used in the production of the good. Therefore, the rule of origin is satisfied and the gin qualifies for USMCA preferential treatment because it meets the requirements of HTSUS General Note 11(b)(iii). The merchandise will therefore be entitled to a free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and agreements. |
| Ruling Date: June 25, 2025 |
N350309: The tariff classification of sample toy packaging from China
| HTS: 9811.00.60, free, “Any sample (except samples covered by heading 9811.00.20 or 9811.00.40), valued not over $1 each, or marked, torn, perforated or otherwise treated so that it is unsuitable for sale or for use otherwise than as a sample, to be used in the United States only for soliciting orders for products of foreign countries.” |
| Item: The first product under consideration is a paperboard box measuring approximately 20” wide by 12 ¾” tall by 4.5” deep. The package is for a Barbie toy set and is clearly printed “Sample Not For Sale”; the term is highlighted in yellow. The second product under consideration is an open tray package with back made of corrugated cardboard. The package is for a Hot Wheels toy and is clearly printed “Sample Not For Sale”; the term is highlighted in yellow. |
| Reason: N/A |
| Ruling Date: June 25, 2025 |
N350339: The country of origin of food wrapping paper
| Origin: Indonesia |
| Item: The paper product under consideration is food wrapping paper. The paper is packaged in rolls and in boxes of sheets. The paper is made from virgin and recycled pulp that are coated with polyamidoamine epichlorohydrin (PAE), rendering the paper greaseproof. The paper weighs 30 to 100 grams per square meter. In the proposed manufacturing scenario, the food wrapping paper is manufactured and coated with PAE in Indonesia. The master rolls are shipped to China where they are printed, cut to width, and rewound on cardboard tubes to desired lengths. Under a second scenario, the master rolls are shipped to China where they are cut to length and width and packaged in boxes. |
| Reason: The cutting of material to size does not constitute a substantial transformation. Therefore, the country in which the paper is made and coated is the country of origin. The country of origin of the food wrapping paper is Indonesia. |
| Ruling Date: June 25, 2025 |
N350432: The tariff classification of a prefabricated home from Hungary
| HTS: 9406.10.0000, 9903.01.25, 2.6% + 10%, “Prefabricated buildings: Of wood.” |
| Item: The product under consideration is freestanding, unassembled, prefabricated wood buildings. The buildings are constructed primarily of timber and engineered structural timber products, such as cross-laminated timber and glulam. The framing of the building is predominantly wood. The buildings are fully constructed before importation and shipped in parts in one to three containers. Once in the US, the homes are fully assembled on site from the imported components. The homes are not imported with fixtures, appliances, or furniture. Architectural renderings show houses constructed with multiple rooms including bedrooms, bathrooms, living spaces, kitchens, and garages. The buildings are of sturdy construction and are designed to withstand the elements. |
| Reason: The buildings of this heading may or may not be equipped. However, only built-in equipment normally supplied is to be classified with the buildings. This includes electrical fittings (wiring, sockets, switches, circuitbreakers, bells, etc.), heating and air conditioning equipment (boilers, radiators, air conditioners, etc.), sanitary equipment (baths, showers, water heaters, etc.), kitchen equipment (sinks, hoods, cookers, etc.) and items of furniture which are built in or designed to be built in (cupboards, etc.). Tools, appliances, and furniture imported with the prefabricated housing structure are not built-in equipment normally supplied with a building, and therefore must be classified separately. Electrical wiring, HVAC systems, sanitary equipment (baths, sinks, toilets), and cabinets are examples of goods that are classified with the prefabricated building. |
| Ruling Date: June 25, 2025 |
N350433: The country of origin of the LED lighting fixtures
| Origin: Korea |
| Item: The merchandise at issue is identified as SFP800 LED Sporting Fixture (LED sporting lighting fixture). The LED sporting lighting fixtures are identical in design to the complete lighting fixture units but without the (power supply) driver. They are designed for illuminating large-scale sports venues such as stadiums, arenas, and professional sports fields to ensure optimal visibility during games and events held during nighttime or low ambient light conditions. Each of the lights consists of a die-cast aluminum housing, which holds multiple LED modules (LED light source) and precision optics. The products are designed to be mounted on sports lighting poles or stadium roof structures using adjustable mounting brackets. The manufacturing process starts with the production of the LED PCB (Printed Circuit Board) SMD (Surface Mount Device) modules (the light source) in South Korea. Upon receipt of components and materials from China, Vietnam and local suppliers, the Korean factory undergoes assembly procedures. Modules that passed the inspection go through OQC (Outgoing Quality Control), then are shipped to the factory in Vietnam. The factory in Vietnam will produce the light housings, gaskets, etc., and then combine these Vietnamese-origin components and materials and other components and materials imported from South Korea, Germany and China to make the finished LED sporting lighting fixtures. |
| Reason: The Korean-originating PCBs with the LEDs populated, which are the light sources and the considered the most important components of the LED lights, have a pre-determined end-use when imported into Vietnam. They do not undergo a change in use due to the assembly process in Vietnam. Therefore, the country of origin of the LED sporting lighting fixtures will be Korea. |
| Ruling Date: June 25, 2025 |
N349423: The tariff classification of steel wheel nuts and flange bolts from Mexico
| HTS: (wheel nut) 7318.16.0015, 9903.01.33, 9903.81.90, 9903.01.01, free + 25% + 25%, “Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Nuts…Lugnuts: Non-locking chrome plated.” (flange bolt) 7318.15.8066, 9903.01.33, 9903.81.90, 9903.01.01, 8.5% + 25% + 25%, “Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Other: Having shanks or threads with a diameter of 6 mm or more: Other: Other: With hexagonal heads: Other: Cap screws.” |
| Item: The first item under consideration is described as an automotive wheel nut, which is made of chrome-plated steel. Wheel nuts are commonly referred to as “lug nuts” and serve as essential fasteners that secure wheels to vehicles. They are specifically engineered for automotive wheel fastening. The second item under consideration is described as a flange bolt, which is made of steel, has a flanged hex head, is partially threaded, and measures 8 mm in diameter and 100 mm in length. It is used to attach a compressor. |
| Reason: N/A |
| Ruling Date: June 24, 2025 |
N349547: Country of origin determination for quilted mattress pads and bed rest pillow cover
| Origin: Vietnam |
| Item: A queen size quilted mattress pad made of five layers. A pillow cover for a bedrest pillow. The front of the pillow cover is made from dyed 100 percent polyester faux fur knit pile fabric laminated to 100% polypropylene nonwoven fabric. The manufacturing operations for the mattress, are as follows: In China, yarns for the top fabric are produced. Polyester nonwoven (layer 3) is formed. Waterproof barrier (nonwoven fabric laminated to TPU) is formed. Polyester knit skirt fabric is formed. Elastic, care labels and law labels are made. Yarn, fabrics (on rolls), elastic, and labels are shipped to Vietnam. In Vietnam, Polyester microfiber top fabric (layer 1) is woven, bleached and finished. Polyester batting (layer 2) is formed. Thread is produced. Fabrics are cut. Fabrics are quilted (layers 1, 2 and 3). Components are assembled by sewing. The finished mattress pad is tested, inspected, packaged, warehoused, and exported into the United States. The manufacturing operations for the pillow cover are as follows: In China, polyester faux fur pile front fabric is knit and dyed. Polypropylene nonwoven fabric is formed. Polyester faux fur knit pile fabric and polypropylene nonwoven fabric are laminated. Zippers and labels are made. Faux fur knit pile laminated fabric on rolls, zippers and labels are exported to Vietnam. In Vietnam, polyester micro mink plush back fabric is knit and dyed. Fabrics are cut and assembled by sewing into finished bedrest pillow cover with handle. The bedrest pillow cover is packaged and exported into the United States. |
| Reason: The country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, Vietnam. |
| Ruling Date: June 24, 2025 |
N349574: The tariff classification of a woman’s rain boot from China
| HTS: 6405.90.9060, 9903.01.24, 9903.01.25, 12.5% + 20% + 10%, “Other footwear: Other: Other: Other.” |
| Item: The Blue Mountain™ Mid Cut Farm Print Boot is an above-the-ankle woman’s rain boot. The boot’s upper and outer sole are comprised of molded rubber/plastics. The rubber/plastics lug outer sole has a thick application of leather flocking covering most of the external surface that contacts the ground. The leather material is visible and tactile on the surface and completely obscures the rubber/plastics underneath. The constituent material of the outer sole is considered “other than rubber/plastics.” |
| Reason: N/A |
| Ruling Date: June 24, 2025 |