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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N349676: The tariff classification of gloves from Pakistan
| HTS: 4203.29.1500, 9903.01.25, 14% + 10%, “Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Other: Gloves of horsehide or cowhide (except calfskin) leather: Other: With fourchettes or sidewalls which, at a minimum, extend from fingertip to fingertip between each of the four fingers.” |
| Item: A multi-use glove with a palm side from fingertips to wrist constructed of cow leather, which has been treated to make it waterproof. The back side is constructed of cow leather and a textile fabric. The glove features fourchettes, neoprene knuckle protection, a neoprene cuff with a hook and loop wrist closure and a pull tab. |
| Reason: The essential character of the glove is imparted by the palm side cow leather. |
| Ruling Date: June 25, 2025 |
N349697: The tariff classification of aluminum crop ends from Korea
| HTS: 7602.00.0097, 9903.01.25, free + 10%, “aluminum waste and scrap: other recyclable aluminum...” |
| Item: The products under consideration are identified as aluminum “crop ends,” which are the end sections that are cut off from a billet. Primary aluminum that is sourced from India, Australia, and Russia is sent to Korea where it is melted, cast into a billet, homogenized, and the ends are cut. The billets are made from type 6061 and 6063 aluminum alloy. Once the ends are cut off, they are imported into the United States and sold to customers who will melt the crop ends and make them into new billets. The aluminum “crop ends” subject to this request are of an inconsistent chemistry, are not uniform in size, have physical defects (i.e., cracks, bubbles, etc.) resulting from the casting process, and are leftover scrap from the manufacturing of the billets. |
| Reason: N/A |
| Ruling Date: June 25, 2025 |
N349766: The country of origin determination for a pet bed
| HTS: 6307.90.9891, 9903.01.24; 9903.01.25; 9903.88.15, 7% + 20% + 10% + 7.5%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Origin: China |
| Item: The “Pumpkin Donut Bed,” is a pet bed intended to be used as a comfortable place for a pet to sleep. The pet bed consists of a pet bed cover and two removable cushion inserts. The pet bed cover is composed of two types of textile fabrics. A dyed 100% polyester knitted faux rabbit fur fabric comprises the sides and top of the bed and a dyed 100% polyester woven oxford fabric coated with dioctyl terephthalates (DOTP) resin comprises the bed bottom. The bolster and bottom insert are composed of an outer shell of 100% polypropylene nonwoven fabric stuffed with 70% polyurethane shredded foam and 30% polyester fiberfill. The manufacturing operations for the pet bed are as follows: In China: 100% polyester faux rabbit fur fabric is knitted, dyed, and shipped in rolls to Vietnam or Cambodia. In Vietnam or Cambodia: Fabric is cut and sewn. Cushion inserts are stuffed, inserted into pillow cover, and zippered closed. The finished pet bed is packaged and shipped to the United States. |
| Reason: The pet bed is comprised of two textile fabrics sewn together, and each of these fabrics are formed by a fabric-making process in a single country, that is China. Therefore, pursuant to 19 CFR 102.21(c)(2), the country of origin of the pet bed is China. |
| Ruling Date: June 25, 2025 |
N349787: The tariff classification of a spot-welded assembly of steel sheets from the Republic of Korea
| HTS: 7326.90.8688, 9903.81.90; 9903.01.33, 2.9% + 50%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The item under consideration is described as a spot-welded assembly of two rectangular stainless steel sheets. Both sheets feature rectangular and diagonal notching at the corners. The sheets are spot-welded together at the midpoint edge of the long parallel sides. The assembly’s interior sheet is composed of 409L stainless steel. The assembly’s exterior sheet is composed of 432L stainless steel and is embossed with a brand logo. |
| Reason: N/A |
| Ruling Date: June 25, 2025 |
N349925: The country of origin of a kava based product
| Origin: China |
| Item: The items under review go under the product name “KavaKalm Kava Extract 30%” and contain six different kavalactone compounds (Kavain, Dihydrokavain, Methysticin, Dihydromethysticin, Yangonin, and Desmethoxyyangonin) which are present after having been extracted from kava plants. KavaKalm Kava Extract 30% will be used as an ingredient in food, beverage, pharmaceutical, and cosmetic products. Kava plants from Vanuatu are harvested and sent to China where they undergo testing and a supercritical extraction with carbon dioxide. After that, they undergo a concentration and spray drying process with corn maltodextrin, and corn starch. A dry extraction and testing of the semi-finished product then occurs after which the product is grinded and sifted, mixed, placed in inner packaging, tested again, and then placed in outer packaging for exportation. |
| Reason: Kavalactones present inside a kava plant undergo several processes in order to be extracted, combined with corn maltodextrin, and corn starch, and are ultimately turned into a powdery substance suitable for further manufacturing into other products. The kava plant of Vanuatu origin has undergone a substantial transformation. The operations performed in China result in a product with a different name, character, or use. The essential character of the kava based product has changed. Accordingly, the country of origin of the finished product is China. |
| Ruling Date: June 25, 2025 |
N349930: The tariff classification of air dryers from South Korea
| HTS: 8414.80.9000, 9903.01.25, 3.7% + 10%, “Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not fitted with filters; parts thereof: Other, except parts: Other.” |
| Item: The products in question are mechanical air dryers, specifically the AW model series. Each dryer features an inlet that receives compressed air and two notched pieces that incorporate shafts. In use, the two aluminum pieces are rotated to correspond to the outer diameter of the cable jacket. Once the cable jacket is inserted and enclosed between the notches, compressed air travels through the orifices to be concentrated in the cable jacket for the purpose of removing moisture. The air dryers, which are imported in a package of three, are designed to be mounted on a stand or screwed onto the wall of a trough. |
| Reason: N/A |
| Ruling Date: June 25, 2025 |
N349985: Classification and country of origin determination for a pet bed
| HTS: 6307.90.9891, 9903.01.24; 9903.01.25; 9903.88.15, 7% + 20% + 10% + 7.5%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Origin: China |
| Item: The item described as a “Donut Pet Bed,” is a pet bed intended to be used as a comfortable place for a pet to sleep. The pet bed is composed of two types of textile fabrics. A dyed 100% polyester knitted polyvinyl chloride fabric comprises the sides and top of the bed and a dyed 100% polyester woven fabric coated with dioctyl terephthalates (DOTP) resin comprises the bed bottom. The pet bed is stuffed with 100% polyester fiberfill and sewn closed. The manufacturing operations for the pet bed are as follows: In China: the polyester polyvinyl chloride fabric is knitted, dyed, and shipped in rolls to Cambodia. In Cambodia: the polyester thread is produced. Fabric is cut and sewn. Pet bed is stuffed and sewn closed. The finished pet bed is packaged and shipped to the United States. |
| Reason: The pet bed is comprised of two textile fabrics sewn together, and each of these fabrics are formed by a fabric-making process in a single country, that is China. Therefore, pursuant to 19 CFR 102.21(c)(2), the country of origin of the pet bed is China. |
| Ruling Date: June 25, 2025 |
N350079: The country of origin of a replacement water filter
| Origin: U.S. |
| Item: The eSpring e3 Carbon Filter for the eSpring Water Treatment System. The filter uses a three-layer filtration system to filter and purify water. The eSpring e3 Carbon Filter is assembled in China using components manufactured in the United States and China. The filter comprises a U.S. origin carbon block, and Chinese origin adhesive, pre-filter, outer wrap, top endcap and bottom endcap. The carbon block is the most expensive portion of the filter and also performs the primary filtering function for the system. The assembly process in China starts with gluing and attaching the outer wrap to the exterior of the carbon block. Then, a worker applies the o-ring to the top end cap. This is followed by applying glue to both the top cap and bottom cap and attaching them to the carbon block. Next, the pre-filter is inserted over the filter assembly before shrink-wrapping the filter. Finally, the filter is tested, labeled, and packaged for final shipment to the United States. |
| Reason: Regarding the origin of the eSpring e3 Carbon Filter, the assembly process predominantly involves screwing, gluing and pressing various components into place. The combining of these parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the replacement water filter, it is the origin of the carbon block, which provides the essential function of the filter. It is the carbon block from the U.S. which requires considerable technical experience and customized equipment to produce. It is also the most expensive portion of the filter, and it is the item performing the filtering of the water. Accordingly, the country of origin of the eSpring e3 Carbon Filter will be the U.S., which is where the carbon block is manufactured. |
| Ruling Date: June 25, 2025 |
N350082: The country of origin of a replacement water filter
| Origin: U.S. |
| Item: The Calypso Water Filter, which is a replacement water filter used with the eSpring Water Treatment System. The filter uses a multi-stage process to purify water, combining a carbon-block filter with a UV lamp. The Calypso Water Filter is assembled in China using components manufactured in the United States, China, and Hungary. The filter comprises a United States origin carbon block, adhesive, and outer wrap. The Chinese origin components include the endcap cover, quartz retainer ring, lamp printed circuit board assembly (PCBA), crimped reflector, o-rings, bumper band, open end cap and radio frequency identification (RFID) assembly, quartz tube, and closed end cap. The UV lamp assembly is produced in Hungary. The assembly process in China starts with gluing and attaching the outer wrap to the exterior of the carbon block. This is followed by applying glue to both the open and bottom end caps and reflector to the filter assembly. Then, the reflector is inserted into the carbon filter assembly and the quartz sleeve is inserted into the reflector. Next, the lamp PCBA is pre-attached to the UV lamp before the UV lamp assembly is inserted into the quartz tube inside the filter assembly. The RFID is then inserted within the top cap and glued in place before testing and labeling. Finally, the o-ring is placed on the final assembly and closed with the top cap before packing and shipping to the U.S. |
| Reason: The assembly process predominantly involves screwing, gluing and pressing various components into place. The combining of these parts in China does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the country of origin of the replacement water filter, it is the origin of the carbon block, which provides the essential function of the filter. It is the carbon block from the United States which requires considerable technical experience and customized equipment to produce. It is also the most expensive portion of the filter, and it is the item performing the filtering of the water. Accordingly, the country of origin of the Calypso Water Filter will be the U.S., which is where the carbon block is manufactured. |
| Ruling Date: June 25, 2025 |
N350121: The country of origin of a weed cutter
| Origin: Vietnam |
| Item: The weed cutter is a hand-held tool used to cut grass and weeds. The tool has a long handle attached to a double-edged serrated blade. When operating the tool, a user swings the tool back and forth through the vegetation that needs cutting. The manufacturing process for the weed cutter begins in Vietnam, where Chinese-origin hot-rolled steel is laser-cut and heat-formed into the double-edged serrated blade. Raw steel is also stamped, cut and bent into the two brackets that attach the blade to the handle. The serrated blade and brackets are then sent to China, where they heat-treated, powder coated, polished and assembled with a Chinese-origin wood handle. Finally, a plastic grip is attached to the end of the handle. |
| Reason: The hot-rolled steel is substantially transformed in Vietnam into the fully formed double-edged serrated blade of the weed cutter. It is the serrated blade that imparts the essence of the finished weed cutter. Based upon the finishing and assembly operations performed in China, the double-edged serrated blade is not substantially changed so as to transform it into a new article with a different name, character, or use. The country of origin of the finished weed cutter is Vietnam. |
| Ruling Date: June 25, 2025 |