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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N350091: The country of origin of a pen
| Origin: India |
| Item: The merchandise under consideration is described as model #693 Aluminum Pen. All parts including the touch, plunger ring, clip base, clip, barrel, spring, tip, and runner are sourced in China. The refill (ink cartridge) is sourced in India. All components will be shipped to China for assembly of components. The assembly process takes place in China. The assembly of pen is taking the refill, putting it into the barrel, and clipping the ears and nose cone with main components. |
| Reason: The ink is injected into cartridges in India. The refill (ink cartridge) is sourced in India. The Indian origin ink cartridge resulted in a substantial transformation of the components. The assembly of the components in China does not constitute a change in name, character, or use. |
| Ruling Date: July 1, 2025 |
N350095: The country of origin of four pens
| Origin: Switzerland, Germany and India |
| Item: The merchandise under consideration is pens available in a variety of colors. All parts are sourced in China for each pen except the refill (ink cartridge). The refill (ink cartridge) is sourced from the following countries: #281-Ball Pen: Switzerland #587-Ball Pen: Germany #207-Eco Pen and #313 Pen: India. All components will be shipped to China for assembly of components. The assembly process takes place in China for each pen. The assembly of each pen is taking the refill, putting it into the barrel, and clipping the ears and nose cone with main components. |
| Reason: The assembly of the components, including the ink cartridges, in China is simple and does not constitute a change in name, character, or use. Accordingly, the individual components are not substantially transformed in China. The ink cartridge refills, which are manufactured in Switzerland, Germany and India by injecting ink into cartridges, impart the identity of the pens. |
| Ruling Date: July 1, 2025 |
N350113: The country of origin of golf club heads
| Origin: Vietnam |
| Item: The goods under consideration are titanium golf club heads. Raw materials, including titanium, are sourced from Taiwan and exported to Vietnam. In Vietnam: Wax tree assemblies for the golf club heads are produced through wax injection and molding operations and assembled into casting trees. Ceramic shelling is affixed around the wax tree assemblies through repeated coating, dipping, and drying. The wax tree assemblies are placed in a furnace to burn out the wax from the ceramic shell. The now-ceramic trees are heated in a high temperature furnace, after which molten titanium metal is poured into the trees. After cooling, the ceramic is separated from the metal castings and excess material is removed. The golf club heads are exported from Vietnam to China. Tip adapters are manufactured in Taiwan and exported to China. In China: The golf club head bodies are ground. The golf club head faces are welded onto the bodies, and the faces are then ground, polished, and engraved. The tip adapters are attached. The golf club heads are coated, screws are attached, and logos are lasered to the faces. The golf club heads are packaged for shipment and exported to the United States. |
| Reason: The manufacturing operations performed in Vietnam to produce the golf club heads impart the essence of these articles. The casting processes used to transform the raw materials into the final shape of the golf club heads take place in Vietnam. The finishing processes performed in China enhance the aesthetics of the casted golf club heads. The items are not substantially transformed by the processes performed in China. Based on the facts presented, the country of origin of the titanium golf club heads is Vietnam. |
| Ruling Date: July 1, 2025 |
N350122: The tariff classification of an unloading robot system from South Korea
| HTS: 8428.90.0390, 9903.01.25, free + 10%,: “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery: Other.” |
| Item: The merchandise under consideration is referred to as a Mobile Box-handling Robot, model number MBR-6, and consists of a self-propelled mobile base, a singulation conveyor, and two articulated robotic arms (each with a payload capacity of 20 kilograms). The robot is designed to unload loose cartons from shipping containers or other cargo transport vehicles using end-effectors equipped with a vacuum pad and wide-area roller, which is described as a friction-based roller that drags or pushes items. The cargo is unloaded onto the conveyor mechanism, which separates and aligns the cartons into a single-file line. Once the cartons reach the end of the conveyor, they are manually unloaded by a worker or transferred to a separate conveyor system. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N350128: The tariff classification of Solvent Yellow 172 from India
| HTS: 3204.19.2595, 9903.01.25, 6.5% + 10%, “Synthetic organic coloring matter, whether or not chemically defined; preparations 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: Other, including mixtures of coloring matter of two or more of the subheadings 3204.11 to 3204.19: Solvent dyes and preparations based thereon: Other: Other: Other.” |
| Item: The subject product is identified as Solvent Yellow 172, CAS # 68427-35-0, and Product Code FP-402. This product’s molecular formula is C20H19N3O5S. Solvent Yellow 172 is a bright yellow fine powder dye, which is soluble in organic solvents. The dye will be imported quantities of 100 kilograms. Solvent Yellow 172 is used as a colorant in various applications. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N350170: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: Five models of a fiber optic patch cord assembly, which are fiber optic cables that consist of a fiber optic core, which consists of 2, 64, or 288 optical fibers depending on the model number. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the U.S. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and prepared for the addition of the connectors, which are sourced from China. The connectors are then assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S. |
| Reason: The fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce. |
| Ruling Date: July 1, 2025 |
N350200: Country of origin determination for comforter set
| Origin: Vietnam |
| Item: The subject merchandise, prototype “OPP BIAB,” described as a “Bed in a Bag (BIAB) Set,” consists of a comforter, flat sheet, fitted sheet, pillowcases, and shams. All items are made from 100% polyester brushed microfiber woven fabric. The open end of the pillowcase features a 2-inch self-hem. The manufacturing operations for the “BIAB Set” are as follows: In Vietnam, all fabric is woven and formed. All fabric is exported in rolls to China. In China, batting for comforter is formed. Elastic band for fitted sheet is formed. All fabric is washed and either dyed or printed. All fabric is cut and assembled by sewing into fitted sheets, flat sheets, pillowcases, shams and comforters. All finished articles are packaged ready for sale and exported to the United States. |
| Reason: The fabric-making process of the subject comforter’s outer shell constitutes the most important manufacturing process. Accordingly, the fabric-making process in Vietnam, where the fabric for the outer shell is formed, constitutes the most important manufacturing process and the country of origin for the comforter is Vietnam. |
| Ruling Date: July 1, 2025 |
N350308: The tariff classification of samples of toys and toy components 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: A Barbie Playset, Hot Wheels Track Set, Polly Pocket Compact Playset, and Barbie Reveal Playset. With the exception of the Barbie Reveal Playset, each item is actually a component of the identified toy. Each submitted item is marked “Sample Not for Sale” with a pressure-sensitive label affixed to the item. In each case, the label cannot be removed without damaging the item. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N350327: The tariff classification of women’s knit blouses from Vietnam and the Dominican Republic
| HTS: 6106.10.0010, 9903.01.25, 19.7% + 10%, “Women’s or girls’ blouses and shirts, knitted or crocheted: Of cotton: Women’s.” |
| Item: Style A is a women’s blouse constructed from 100% cotton jersey knit fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from the shoulders to below the waist and features a rib-knit crew neckline, contrasting color letters located on the upper front panel, short, hemmed sleeves, and a hemmed bottom. Style B is a women’s blouse constructed from 100% cotton jersey knit fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from the shoulders to below the waist and features a rib-knit crew neckline, a contrasting color logo on the upper portion of the front panel, short, hemmed sleeves, and a hemmed bottom. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N350342: The country of origin of aluminum mop poles
| Origin: Vietnam |
| Item: Two-piece aluminum mop poles which are an assembly of two machined aluminum pipe profiles and various injection molded plastic components. Manufacturing begins in China where plastic pellets are combined with coloring, mixed, and injection-molded to form various plastic parts, such as handle surfaces and parts for connection to other objects. In Vietnam, aluminum pipe profiles from Vietnam are cut according to specifications to form the inner and outer poles. After cutting to length, a groove is clamped on the outer pole by a channeling machine. Following that, the inner pole is chamfered by a chamfering machine and processed by a dotting machine to create a clamping joint. At that point, a punching machine forces one of the plastic parts into one end of the inner pole where it is held in place. Finally, the poles are assembled with the remaining plastic parts and packaged for export. |
| Reason: The aluminum profiles from Vietnam provide the core functionality of the finished aluminum mop poles because they are the rigid structural component that enables a user to efficiently manipulate a mop during use. Although the finished mop poles feature injection-molded plastic components from China, they are primarily supportive, less-significant components which are subservient to the role of the aluminum profiles. In totality, when the functionally predominant aluminum profiles from Vietnam are assembled with the less-significant plastic components from China, they are not substantially transformed. |
| Ruling Date: July 1, 2025 |