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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N350822: The tariff classification of a tool set from China
| HTS: 8466.10.0175, 9903.01.24; 9903.01.25; 9903.88.01, 3.9% + 20% + 10% + 25%, “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for the machines; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Other.” |
| Item: A 20-piece tool set which will be imported with a tin exterior hard case, ready for retail sale. The contents of the tool set are as follows: 1 - Pair of pliers, 1 - Measuring tape, 1 - Driver handle, 1 - Driver extension, 5 - Sockets, 10 - Screwdriver bits. |
| Reason: N/A |
| Ruling Date: July 2, 2025 |
N349663: The tariff classification of seal carriers from South Korea
| HTS: 8708.80.6590, 9903.94.05; 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” |
| Item: The articles under consideration are seal carriers: Seal Cap, Carrier Sealing, and Carrier Sealing, which are designed for electric vehicles. The seal carriers are coupled at the bottom of the air spring within the vehicle’s air suspension tower. By sealing air, they contribute to maintaining the air suspension system’s pressure and ensuring its normal operation. The seal carriers are made of 100% aluminum alloy. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N349799: The tariff classification of an insulin delivery device from China
| HTS: 9817.00.96, free, “articles and parts and accessories of articles specifically designed or adapted for the use or benefit of the permanently or chronically physically or mentally handicapped.” |
| Item: The V-Go wearable insulin delivery device (all-in-one insulin delivery patch) is a fully mechanical, disposable device designed for diabetic users. It is worn like a patch for 24 hours and provides continuous subcutaneous insulin infusion over 24 hours at a preset basal rate. The device includes a button cover which covers the start button and prevents it from being pushed, an insulin port, a bolus ready button, a viewing window with an indicator to show a view of the insulin reservoir, a bolus delivery button, a needle release button, and an adhesive pad and liner on the bottom of the device. The V-Go is imported without insulin pre-filled. |
| Reason: The V-Go is specifically designed to provide precise, 24-hour insulin delivery for diabetic persons in a home setting. Therefore, the V-Go is specifically designed for use by the handicapped and qualifies for duty-free treatment under subheading 9817.00.96. |
| Ruling Date: July 1, 2025 |
N349876: The tariff classification of a bar mixer set from India.
| HTS: 8215.20.0000 / 7323.93.0060, 9903.81.90, 9903.01.33, 2% + 50%, “[s]poons, forks, ladles, skimmers, cake-servers, fish-knives, butter-knives, sugar tongs and similar kitchen or tableware; and base metal parts thereof: [o]ther sets of assorted articles.” |
| Item: The product under consideration is described as a bar mixer set, and it includes a bar spoon, ice tongs, strainer, jigger, bottle opener, peeler, and a leather case which houses the preceding items. The bar spoon is made wholly of stainless steel and the other bar tools are made of stainless steel with riveted walnut wood handles. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N349899: The country of origin of gaming laptops
| Origin: Vietnam |
| Item: Five models of automatic data processing (ADP) machines referred to as Razer Blade 16 Gaming Laptop personal computers (PCs). The manufacturing process for all five models of the Razer Blade 16 gaming laptops is the same. The motherboard printed circuit board assemblies (PCBAs) are assembled in Vietnam using components sourced from various countries of origin. The production of the PCBA starts with a blank printed circuit board (PCB) and advances through many steps, using surface mount technology (SMT), laser etching, solder paste application, accurate pick and placement of the components through a reflow oven, and auto-inspection and testing of the parts. Once the motherboard PCBA is tested and completed, it is then shipped to China where the Razer Blade 16 gaming laptops are assembled. Each assembly process consists of inserting the PCBA onto the bottom cover and attaching the webcam, OLED panel, wireless antenna, keyboard, fan, lithium battery, etc., into the housing. Lastly, these laptop PCs are inspected, tested, labeled, and are packaged for export into the United States. |
| Reason: The assembly of the motherboard PCBA in Vietnam, via surface mount technology (SMT), laser etching, solder paste application, accurate pick and placement of small components, and permanent connection of the components through a reflow oven results in a substantial transformation of those components to produce a motherboard PCBA of Vietnam origin. Furthermore, the motherboard PCBA is the dominant component of the laptop PC because it is the article within the assembly that houses and controls the interconnection of the processor, CPU, memory, and contains the BIOS that permits the ADP machine to function. The assembly work conducted in China, which entails inserting, plugging, and fastening, does not substantially transform the motherboard PCBA into a new and different article. Therefore, the Razer Blade 16s, are considered products of Vietnam for origin purposes at the time of importation into the U.S. |
| Ruling Date: July 1, 2025 |
N349914: The tariff classification of Ethinyl Estradiol/Drospirenone Tablets in dosage form, from India
| HTS: 3006.60.0000, 9903.01.32, free, “Pharmaceutical goods specified in note 4 to this chapter: Chemical contraceptive preparations based on hormones, on other products of heading 2937 or on spermicides.” |
| Item: Ethinyl Estradiol/Drospirenone, imported in 3 mg/0.02 mg tablets, is a medicinal preparation containing a combination of Ethinyl Estradiol (a steroidal estrogen) and Drospirenone (a synthetic progestin), as the active ingredients. It is indicated for use as an oral contraceptive for the prevention of pregnancy. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N349972: The country of origin of a bicycle helmet
| Origin: Taiwan |
| Item: A hard-shell ventilated bicycle helmet. The outer shell is constructed from Acrylonitrile Butadiene Styrene (ABS) plastic, while the inner lining consists of Expanded Polystyrene (EPS) foam. The production process for the helmet begins in Taiwan with pre-production quality control, followed by drying the ABS raw material and performing injection molding to form the shell. Once molded, the shell is cooled and ejected, then hand-trimmed and sanded or buffed to remove mold lines. After surface finishing, the shell undergoes final inspection and quality control. Production then moves to China, where the EPS liner is injected and formed. Various components are then added. A metal plate is heat staked into the shell, the fit system and poplock are molded, magnets are glued into the poplock and elastic strings are attached. Straps and buckles are sewn together, and both the shell and poplock are painted. Decals are applied, piping is glued onto the shell, and the straps are riveted in place. For final assembly, the EPS liner is installed and glued into the shell, and all remaining components -- fit system, padding, and polo -- are installed to complete the helmet. |
| Reason: The production process conducted in China does not result in a new and distinct article of commerce that has a different name, character or use compared to its individual components. Therefore, to determine the country of origin of the bicycle helmet, it is the outer shell, that imparts the essential identity to the helmet and is also the most costly component of the product. |
| Ruling Date: July 1, 2025 |
N349989: The country of origin of LAN cables
| Origin: Mexico |
| Item: The merchandise under consideration is a CAT6 Unshielded Twisted Pair (UTP) LAN cable. The cable is constructed of multiple insulated pairs within an outer jacketing. The cable is imported on reels and is not terminated with any connectors. There are two proposed versions of the manufacturing process. In the first version, Taiwanese copper wire is imported into Mexico on reels. This copper wire is then drawn to decrease its diameter and increase its length. The drawn wire is then annealed before it is extruded to add a layer of insulation, which originates from Japan. Two insulated wires are then wound together in order to create what is referred to as an insulated pair. Multiple insulated pairs are then combined together and further insulated via the extrusion process with insulation material from China in order to create the finished cable. The finished cable is then tested and wound onto a reel in preparation for export to the United States. The second version of the manufacturing process is virtually identical to that which is described above. The only difference is U.S. origin copper wire is imported into Mexico. The remainder of the process stays the same. |
| Reason: The process completed in Mexico, including the drawing, annealing, insulating, winding, and bundling is significantly complex to substantially transform the copper articles. Though at importation into Mexico the copper wire has some electrical capabilities, the work described above significantly adds to the electrical properties consistent with the use of the finished cable. |
| Ruling Date: July 1, 2025 |
N349996: The country of origin of a wireless video game controller
| Origin: Vietnam |
| Item: The merchandise under consideration is the Stealth Ultra Wireless XB/PC Global Controller, which is a wireless video game controller, USB transmitter (Dongle), and a charging dock for the controller. The controller, which is the main item, contains eight printed circuit board assemblies (PCBAs), which have electronic components affixed to a bare printed circuit board (PCB) using Surface Mount Technology (SMT) or Dual In-line Package (DIP) insertion in Vietnam. Firmware is then loaded onto the main PCBA in Vietnam. All eight PCBAs are tested for circuit and functionality in Vietnam. They are then assembled together into a single array and tested for circuit and functionality in Vietnam. The array of eight PCBAs is then packaged and shipped to China. The dongle PCBA is assembled using SMT and tested for circuit and for functionality in Vietnam. It is then packaged and shipped to China for assembly in a Dongle (USB Transmitter). The charger contains three PCBAs that are assembled using SMT and tested for circuit and for functionality in Vietnam, then packaged and shipped to China. In China, the final assembly of each item takes place, including installing the PCBAs into plastic housings. The finished controller, dongle, and charger are then packaged together and shipped to the United States. |
| Reason: The PCBAs contribute to the main functionality of the finished merchandise. The complex SMT manufacturing production of these PCBAs, which includes placement and soldering of numerous individual components onto a bare PCB, creates functional PCBAs that results in a substantial transformation of the components to produce PCBAs of Vietnamese origin. Additionally, the assembly process performed in China would not substantially transform the PCBA of Vietnamese origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. |
| Ruling Date: July 1, 2025 |
N350072: The tariff classification of blood monitoring meters from South Korea
| HTS: 9027.50.4015, 9903.01.25; 9817.00.96, free, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Chemical analysis instruments and apparatus.” |
| Item: The items under consideration are described as high-accuracy prothrombin time/international normalized ratio (PT/INR) test meters. The devices are primarily designed for home and laboratory use, allowing patients with chronic cardiovascular or thromboembolic conditions requiring anticoagulant therapy to monitor their PT/INR levels. The PT/INR meters are available by prescription only and designed for persons with particular diagnoses, including unspecified, chronic, paroxysmal, or persistent atrial fibrillation, acute deep vein embolism and thrombosis, coagulation defects, presence of a prosthetic heart valve, and other conditions which require the long-term use of anticoagulant medications. The meters are all very similar with only a few defining characteristics. |
| Reason: The essential character of the kit is imparted by the PT/INR meter. Secondary classification 9817.00.96 applies to the PT/INR monitoring meters and kit and the kit will be free of duty. |
| Ruling Date: July 1, 2025 |