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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N350472: The tariff classification of “Cards Against Humanity Explains the Joke” from China
| HTS: 4911.99.6000, 9903.01.22; 9903.01.31; 9903.01.32; 9903.88.15, free, “Other printed matter: Other: Other: Other: Printed on paper in whole or in part by a lithographic process.” |
| Item: The item under consideration is a boxed set of printed cards titled “Cards Against Humanity Explains The Joke.” The box contains a deck of cards and an instruction booklet. The cards are printed by means of offset lithography on paper that is coated with plastic. The cards provide background and commentary explaining the context of the company’s “Cards Against Humanity” games. “Cards Against Humanity Explains the Joke” differs from “Cards Against Humanity” in that it is not a game. It has no rules, points, goals, winners, or losers. It is simply meant to be informative for users of the “Cards Against Humanity” games. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N350501: The country of origin of napkins
| Origin: Indonesia |
| Item: The paper products under consideration are "beverage napkins," "luncheon napkins," and "dinner napkins." They come in either single or double ply with 1/2, 1/4 or 1/8 fold. The bulk rolls of napkin stock are manufactured in Indonesia. The paper is White/Kraft 100% wood pulp virgin paper; layer:1-2; 12-25 g/sm. These parent rolls of tissue paper, which measure in multiple widths from 400mm up to 1000mm and have a maximum roll diameter of 1000mm, are then sent to China, where the paper is embossed then cut and folded to length and width. No shaping is done. The napkins are then subjected to quality control and packaged. |
| Reason: In China the napkin stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting, folding and packaging. |
| Ruling Date: July 1, 2025 |
N350506: The country of origin of paper towel
| Origin: Indonesia |
| Item: The paper products under consideration are "hand towel sheets," "center-pull towels," and "hand roll towels." They come in single ply rolls. The bulk rolls of hand towel stock are manufactured in Indonesia. The paper is White/Kraft 100% wood pulp virgin paper; layer:1; 19-42 g/sm. These parent rolls of towel stock paper, which measure in multiple widths from 930mm up to 2850mm and have a maximum roll diameter of 2850mm, are then sent to China, where the paper is unwound, embossed, cut to length and width and rewound or folded. The paper towels are then subjected to quality control and packaged. |
| Reason: In China the paper towel stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by unwinding, embossing, cutting, rewinding or folding and packaging. |
| Ruling Date: July 1, 2025 |
N350656: The country of origin of a tamper
| Origin: China and Vietnam |
| Item: The item under consideration is a tamper. The tamper will be manufactured in two countries, Vietnam and China, and undergo the following two manufacturing scenarios: Scenario one: In Vietnam, raw steel is laser-cut into the 10" x 10" base and the four diagonal reinforcement ribs. These articles are then sent to China, where they are welded together into the fully formed head of the tamper. The tamper head is then welded onto a steel handle. Finally, the steel is powder coated and a soft-grip is applied to the end of the handle. Scenario two: This scenario is the same as the first, except the 10" x 10" base and the four diagonal reinforcement ribs are welded together in Vietnam to form the fully formed head of the tamper. The tamper head is then sent to China where it is welded onto a steel handle. Finally, the steel is powder coated and a soft-grip is applied to the end of the handle. |
| Reason: The tamper is used for tamping down asphalt, gravel, stone, and soil. Without the reinforcement ribs, the flat base would not be able to perform this task. Furthermore, it is the assembly of the base with the ribs that forms the fully formed head of the finished tamper. It is the tamper head that provides the principal characteristics of the finished tamper, is dedicated for use as such, and cannot be used for any other purpose. Therefore, the country of origin of the finished tamper in the first manufacturing scenario is China. Regarding the second manufacturing scenario, a substantial transformation occurs in Vietnam. It is here that the 10" x 10" base and the four diagonal reinforcement ribs are welded together to form the fully formed head of the tamper. It is the tamper head that provides the principal characteristics of the finished tamper, is dedicated for use as such, and cannot be used for any other purpose. Based on the assembly operations performed in China, the tamper head is not substantially changed to transform it into a new article with a different name, character, or use. Therefore, the country of origin of the tamper in the second manufacturing scenario is Vietnam. |
| Ruling Date: July 1, 2025 |
N349750: The tariff classification of two parts from China
| HTS: (Part MA302-1) 9019.20.0000, 9817.00.96, free, “Ozone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus; parts and accessories thereof.” (Newlife Core Tube) 8481.90.9081, 9817.00.96, free, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Parts: Other: Other: Other: Steel forgings.” |
| Item: Part MA302-1 is described as a manifold. It is a metal frame made of stainless steel designed to hold other components and has a unique symmetrical pattern. It features three large holes in the left, right, and center and several screw holes and measures approximately 5.5 inches in length and 1 inch in width. The product is designed with the specific form, fit, and function to be compatible only with the Freestyle Comfort portable oxygen concentrator. Part VA378-1 is described as Newlife Core Tube. It is a valve stem made of stainless steel and measures approximately 2 inches in length and 0.6 inches at its widest points. This component is part of a Valve Manifold (MA198-1), which itself is a component of a Valve Manifold Assembly (VA536-1). The valve manifold assembly is part of Visionaire 5 stationary oxygen concentrator. |
| Reason: Part MA3021-1 and Part VA378-1 are designed with specific dimensions including length and material. These dimensions and design enable them to function as parts of the Comfort portable oxygen concentrator and Visionaire 5 stationary oxygen concentrator, respectively. Based on the information provided, Part MA3021-1 and Part VA378-1 are specially designed as parts of the oxygen concentrators. As such, they qualify for duty-free treatment under subheading 9817.00.96, HTSUS. |
| Ruling Date: June 30, 2025 |
N349793: The country of origin of oral care swabs from Vietnam
| Origin: Vietnam |
| Item: The products under consideration are described as DenTips. They are used similar to a toothbrush to provide oral care. There are two versions, one that is untreated and another that has dentifrice applied. The untreated version features a blue sponge and a polypropylene (PP) stick that are bonded together. The treated version consists of a green sponge, a PP stick bonded to the sponge, and a dentifrice printed onto the surface of the sponge. For the untreated version, the sponge is sourced from Vietnam and the PP stick is from Indonesia. In China, the sponge is glued onto the PP stick using hot melt adhesive. It will then be packaged for export to the United States. For the treated version, the sponge is sourced from Vietnam, the PP stick from Indonesia, and the dentifrice from the United States. In China, the sponge is glued onto the PP stick using hot melt adhesive and then the dentifrice is printed onto the surface of the sponge. It will then be packaged for export to the United States. |
| Reason: The sponge head holds the basic nature of the finished swab and does not become a new article having a new name, character, or use after being attached to the handle in China. Therefore, the origin of the finished oral care swabs will remain the same as the origin of the sponge heads as they are not substantially transformed in China. Accordingly, the country of origin for the treated and untreated versions of the DenTips will be Vietnam. |
| Ruling Date: June 30, 2025 |
N349848: The tariff classification of a plastic plug from China
| HTS: 3926.90.9989, 9903.01.24; 9903.01.25; 9903.88.15, 5.3% + 20% + 10% + 7.5%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” |
| Item: The product under consideration is a silicone plastic plug for use with a water tank in a commercial coffee machine. |
| Reason: N/A |
| Ruling Date: June 30, 2025 |
N349850: The country of origin of four human hair products from India
| Origin: India |
| Item: The products under consideration are hair wefts, wigs, tape-in hair extensions, and clip-in hair extensions. Each of the products are made of human hair harvested and cleaned in India and then shipped to China for construction into the final product. The complete manufacturing process is as follows: 1. The raw human hair is collected in India. 2. The hair is cleaned and prepared for coloring. 3. The hair is then shipped to China and dyed to the desired color. 4. The hair is separated into individual hair strands by length, then reorganized and bundled according to a specific ratio of lengths. 5. Hair extension attachments are affixed to the hair depending on the type of finished product, e.g., a polyurethane base is applied followed by double-sided tape for tape-in extensions. For I-Tip extensions, an adhesive base is shaped into small cylindrical tips. 6. Lastly, the finished product is packaged and prepared for shipment. |
| Reason: The prepared hair holds the basic nature of the finished articles and that it is not substantially transformed to become a new article having a new name, character, or use after being further processed in China. Accordingly, the country of origin for these wefts, wigs, and hair extensions will be India. |
| Ruling Date: June 30, 2025 |
N349912: Country of origin determination for a beach towel and bandannas; 19 CFR 102.21(c)(2); tariff shift
| Origin: China |
| Item: Item 1 is a beach towel made of 100% polyester woven terry toweling. The front of the towel is printed with a colorful design. Item 2 is a 100% cotton woven bandanna. The bandanna is both dyed and printed and measures approximately 26 × 26 inches with hemmed edges. Item 3 is a 100% silk woven bandanna. The bandanna is both dyed and printed and measures approximately 26 × 26 inches with hemmed edges. The manufacturing operations for the beach towel and the bandannas are as follows: In China, fabric is woven. Fabric is dyed (bandannas, only) and printed. Fabric is exported to Cambodia. In Cambodia, fabric is cut to size. Fabric is hemmed. Completed beach towel and bandannas are packaged and shipped to the United States. |
| Reason: As the fabrics forming the cotton bandanna and polyester beach towel are formed by the fabric making process in a single country, that is, China, as per the terms of the tariff shift requirement, country of origin is conferred in China. |
| Ruling Date: June 30, 2025 |
N349917: The tariff classification of heating elements from China
| HTS: 8516.10.0080, 9903.01.24; 9903.01.25; 9903.88.15, free + 20% + 10% + 7.5%, “other instantaneous electric water heaters and immersion heaters.” |
| Item: Each heating element in all models consists of a type 304 stainless steel enclosure and a U-shaped heating element rod. All models have a 6 feet 3-wire grounded cord with plug, and a 1-inch standard NPT male thread for through-the-side tank installation in knife sterilizers with a 1-inch NPT threaded female flange. These models also come with a stainless steel nut and rubber washer for installation in knife sterilizers with a 1.25 inches hole. |
| Reason: N/A |
| Ruling Date: June 30, 2025 |