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:
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
N350784: The country of origin of napkins
| Origin: Indonesia |
| Item: The paper products under consideration are "dinner napkins," "luncheon napkins," and "tall-fold napkins." They come in either single or double ply with 1/4, 1/6 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; 13.5-21 g/sm. These parent rolls of tissue paper, which measure in multiple widths from 340mm up to 600mm and have a maximum roll diameter of 600mm, are then sent to China, where the paper is embossed, 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. The country of origin of the finished napkins is Indonesia. |
| Ruling Date: July 3, 2025 |
N350902: The tariff classification of wooden decorations from China. Correction to Ruling Number N348372
| HTS: (style A) 4911.91.4040, 9903.01.22, 9903.01.31, 9903.88.15, free + 7.5%, “Pictures, designs and photographs: Printed not over 20 years at time of importation: Other: Other: Other. (style B) 9505.10.2500, 9903.01.24, 9903.01.25, free + 20% + 10%, “Festive, carnival or other entertainment articles, including magic tricks and practical joke articles; parts and accessories thereof: Christmas ornaments: Other: Other.” |
| Item: An item identified as a Box Top-Type Christmas Decoration which consists of an assortment of two styles of tabletop decorations made of medium-density fiberboard (MDF). The square shadowbox type decorations have a printed backdrop backing board and displays four small undecorated bottle brush trees made of plastic and iron attached to circular bases along the bottom of the box. The items measure approximately 8” (L) x 1.2” (W) x 8” (H). Both items are sold separately. Style A has a backdrop that reads “Holly Jolly Farm” with the words, “Sleigh Rides,” “Hot Cocoa,” and “Pine – Spruce – Fir” and “Cut & Carry.” Style B has a backdrop that reads “Locally Grown Christmas Trees” and “Pine – Spruce – Fir.” |
| Reason: N/A |
| Ruling Date: July 3, 2025 |
N350922: The tariff classification of the “Dino Carry Case Play Set” from China. Correction to N349756
| HTS: 9503.00.0073, 9903.01.24; 9903.01.25, free + 20% + 10%, “Tricycles, scooters, pedal cars, and similar wheeled toys… dolls, other toys… puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended for use by persons: 3 to 12 years of age.” |
| Item: The article under consideration is a play kit. The plastic carrying case is a toy in the shape of a dinosaur with posable arms and mouth. It is 10.5 inches high by 22 inches wide and has a depth of 4.3 inches. The case features storage compartments that hold eight toy vehicles and four smaller dinosaur figures. Children will derive amusement by using the contents of the set to create their own dinosaur and car displays. The kit is principally designed for the amusement of children ages 3 and older. |
| Reason: N/A |
| Ruling Date: July 3, 2025 |
N349660: The country of origin of a steering wheel
| Origin: Mexico |
| Item: A steering wheel intended for use with certain Lexus passenger vehicle models. The steering wheel is made using an aluminum diecast armature. The base wheel is made of polyurethane (PU) and incorporates heating elements while wrapped in leather. Once imported into the U.S., a bezel will be added to complete the finished steering wheel. The aluminum diecast armature and PU base is manufactured in the U.S. and shipped to Mexico for further assembly. The heating sensor elements and thread of Vietnamese origin, leather from Italy, and wood elements from Japan are sourced in the United States and shipped to Mexico for use in the production of the steering wheel assembly. In Mexico, the leather wrap and heating elements are assembled into the PU wheelbase. The cutting, skiving, sewing of the leather into the steering wheel loop shape is also performed in Mexico. Once the loop is completed, it is placed around the base wheel and sewed and stitched by hand. The wood elements are inserted to finalize the steering wheel before being inspected and packaged for export to the U.S. |
| Reason: The steering system is classifiable in subheading 8708.94 and the parts (diecast armature, wheel base, heating elements, and bezel) are classified in other headings. Therefore, the tariff shift is met and the country of origin of the steering wheel is Mexico. |
| Ruling Date: July 2, 2025 |
N349664: The tariff classification of a strut mount from South Korea
| HTS: 8708.80.6590, 9903.94.05; 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” |
| Item: A strut mount used in a KIA EV9 model. It consists of a plastic bearing, an aluminum alloy bracket and upper lid, a carbon steel inner plate, a rubber dampener, a plastic outer pipe, and a steel serration bolt. It measures 167.6 mm x 53.7 mm. The strut mount serves to secure the suspension to the chassis and absorbs shocks and vibrations transmitted from the road surface, thereby improving ride comfort. It is mounted at the uppermost part of a vehicle's rear suspension strut assembly and connects the entire strut assembly to the chassis. |
| Reason: N/A |
| Ruling Date: July 2, 2025 |
N349867: The tariff classification of lunch boxes from China
| HTS: 4202.19.0000, 9903.88.03; 9903.01.24; 9903.01.25, 20% + 25% + 20% + 10%, “trunks, suitcases, vanity cases, attaché cases, briefcases, school satchels and similar containers, other.” |
| Item: Hinged, metal lunch boxes, each with a handle. They are designed to provide storage, protection, portability, and organization to a child’s lunch. |
| Reason: N/A |
| Ruling Date: July 2, 2025 |
N349868: The tariff classification of a mechanical insufflation-exsufflation device from the United Kingdom
| HTS: 9019.20.0000, 9817.00.96, free, “[o]zone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus; parts and accessories thereof.” |
| Item: The Clearo MI-E (Mechanical Insufflation-Exsufflation) device is a portable airway clearance device that provides cough modes and therapeutic modes. The cough modes include a manual mode, a basic auto mode, a program auto mode, and a TreatRepeat mode. The therapeutic modes include an Intermittent Positive Pressure Breathing (IPPB, noncontinuous ventilator) mode, and a non-invasive ventilation mode. The device can also be used for oxygen therapy with IPPB. The device is intended for adult or pediatric patients that have compromised secretion clearance and/or a reduced ability to cough effectively. |
| Reason: The Clearo MI-E device satisfies the five factors required for a secondary classification of subheading 9817.00.96. |
| Ruling Date: July 2, 2025 |
N349940: The country of origin of pressure sensors
| Origin: U.S. and Germany |
| Item: Two pressure sensors each manufactured under two scenarios. For the SA87A pressure sensor, materials are gathered from China, Japan, and the U.S. The Chinese components include the cable assembly, PVC retaining nut, epoxy resin, housing, PCBA, O-ring, gilled gel silicone, connecting flexible printed circuit (FPC), sealing ball, header, gold wire, and diaphragm. The oil is from Japan while the silicone and die are produced in the U.S. In the first scenario for the SA87A pressure sensor, the process begins in the U.S. with the creation of the wafers. The manufacturing process then shifts to China where the product is assembled. In the second scenario for the SA87A pressure sensor, the process begins the same way as scenario one but the assembly is in Malaysia. For the SAGF100 pressure sensor, materials are gathered from China, Japan, Germany, and the U.S. The Chinese components include the flexible PCB, header, socket, ceramic bonding PCB, support, and pressure port. Resistors, solder, and solder paste are sourced from Japan, while the strain gauge is from Germany and the glass is from the U.S. In the first scenario for the SAGF100 pressure sensor, the process begins in Germany with German-made wafers containing many strain gauges and supporting structures. The next step includes the wafer dicing to break the wafer into individual strain gauge dies. This is followed by bonding the strain gauge dies onto the diaphragm using adhesive. The manufacturing process then shifts to China where the product is assembled. In the second scenario for the SAGF100 pressure sensor, the process begins in Germany and the assembly takes place in Malaysia. |
| Reason: For the SA87A pressure sensor, the wafer of U.S. origin is the essential component of the finished good in both scenarios. The assembly operations conducted in China or Malaysia do not substantially transform the wafer as a result of encapsulating, soldering, gluing, and welding the wafer with additional components. The wafer is a pressure sensing device when it leaves the U.S. and can only be used as a pressure sensing device when the manufacturing process in China or Malaysia is complete. Therefore, the country of origin of the SA87A pressure sensor in both scenarios is the U.S. For the SAGF100 pressure sensor, the German wafer is the essential component of the finished good in both scenarios. Similar to the results of the SA87A pressure sensor, the assembly operations conducted in China or Malaysia do not substantially transform the wafer as a result of encapsulating, soldering, gluing, and welding the wafer with additional components. Therefore, the country of origin of the second pressure sensor in both scenarios is Germany. |
| Ruling Date: July 2, 2025 |
N349944: The tariff classification of plastic peelable heat shrink tubing from Japan
| HTS: 3926.90.9989, 9903.01.25, 5.3% + 10%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” |
| Item: Heat shrink tubing constructed from a fluoropolymer blend (FEP) which would be considered a plastic material. This tubing serves as a manufacturing aid to apply compression in catheter production processes such as bonding lamination and tip-forming. It is specifically designed for easy removal post manufacturing to minimize removal time and reduce the risk of catheter damage. |
| Reason: N/A |
| Ruling Date: July 2, 2025 |
N349946: The tariff classification of plastic liner tubing from Japan
| HTS: 3926.90.9989, 9903.01.25, 5.3% + 10%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” |
| Item: Liner tubing constructed of polytetrafluoroethylene (PTFE) plastic. This tubing is intended to provide low-friction lumens for guide wire and device delivery and features a high tensile strength and abrasion resistance for catheter durability. |
| Reason: N/A |
| Ruling Date: July 2, 2025 |