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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N350119: Country of origin determination for a duvet
| Origin: China |
| Item: The subject merchandise, described as a “Threshold Cool Touch Duvet Insert,” is a quilted duvet that is intended to be inserted into a duvet cover. The outer shell of duvet is composed of 90% nylon and 10% spandex knitted fabric. The fabric is dyed white and is not printed. The fabric has also been subject to bleaching and weighting. The duvet is stuffed with 100 percent% batting. The manufacturing operations for the quilted duvet are as follows: In China, knit fabric is formed, bleached, dyed, and weighted. Knit fabric is folded and shipped to Vietnam. In Vietnam, polyester batting and thread are produced. Fabrics are cut, sewn, assembled and quilted into a finished quilted duvet insert. Labels and duvet tabs are sewn to the quilted comforter. The finished duvet cover is packaged and shipped to United States. |
| Reason: The fabric-making process of the duvet’s outer shell in China constitutes the most important manufacturing process. Accordingly, the country of origin is conferred by the country in which the most important manufacturing process was performed, that is, China. |
| Ruling Date: July 3, 2025 |
N350182: Country of origin determination for a shade sail
| Origin: Vietnam and China |
| Item: The RTH Shade Sail is designed to be attached to poles over a porch or patio and is intended to provide shade. The shade sail is composed of a 100% high density polyethylene (HDPE) warp knit fabric. A twisted rope is braided between the PE tube and the loop. The pertinent manufacturing operations for the shade sail take place in four scenarios. In all scenarios, in Thailand, 100% HDPE pellets are produced and shipped to either Vietnam or China. |
| Reason: The shade sail comprises fabric that is formed by a fabric-making process in a single country, that is China in Scenario 1 and 2 and Vietnam in Scenario 3 and 4. Therefore, the country of origin of the shade sail in Scenario 1 and 2 is China. For Scenario 3 and 4, the country of origin is Vietnam. |
| Ruling Date: July 3, 2025 |
N350187: The country of origin of laptop computers
| Origin: Vietnam |
| Item: Two “product families” of the Gigabyte Gaming A16 and the Gigabyte Aero X16, which are described as laptop personal computers (PC). The motherboard PCBA for both the Gigabyte Gaming A16 and the Gigabyte Aero X16 is manufactured in Vietnam by affixing numerous components, such as integrated circuits, diodes, resistors, etc. onto a bare printed circuit board (PCB) by means of surface mount technology (SMT). The CPU, graphics processing units (GPU), and video random access memories (VRAMs), sourced from various countries, are affixed to the motherboard PCBA in Vietnam as well. Upon completion of the SMT process for the motherboards, they undergo testing in Vietnam. Once the testing is complete, the motherboard subassembly is shipped to China, where the assembly of the Gigabyte laptop PC is completed by inserting the motherboard and various subassemblies, such as the LCD, keyboard, touchpad, antenna, camera, speakers, daughter board, thermal module, dynamic random access memory (DRAM), SSD, and battery into a housing by attaching cables, fastening with screws, arranging and alignment, and snap-fitting together to produce a functional automatic data processing machine. |
| Reason: The assembly of the motherboard PCBA in Vietnam, by soldering individual components of various origins onto a bare printed circuit board, resulted in a substantial transformation of those components to produce a motherboard of Vietnamese origin. Furthermore, the motherboard PCBA establishes the function of the Gigabyte Gaming A16 and the Gigabyte Aero X16 laptop PC “product families” because it is the article within the assembly that houses and controls the interconnection of the processor, CPU, memory, and contains the BIOS that enables the ADP machine to function. The assembly work conducted in China does not substantially transform the motherboard PCBA into a new and different article. |
| Ruling Date: July 3, 2025 |
N350223: Classification and country of origin determination for a cushion
| HTS: 9404.90.2090, 9903.01.25, 6% + 10%, “Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Other: Pillows, cushions and similar furnishings: Other: Other.” |
| Origin: Vietnam |
| Item: The subject merchandise is described as a “high back cushion (HBC) insert.” The cushion is made of 100% polyurethane (PU) foam covered with nonwoven fabric. The cushion has a round shape on one side and square corners on the other side. The item is the inner core of a cushion typically covered with a decorative cushion cover. The cushion insert will be sold at retail in its imported condition as a replacement cushion or to purchase with a separately sold cover. The manufacturing operations for the cushion insert are as follows: In Vietnam, Polypropylene nonwoven fabric is formed. Polypropylene nonwoven fabric is exported to China. In China: PU foam is formed. Polypropylene nonwoven fabric is cut and sewn into cushion shell. PU foam is inserted into nonwoven shell. Nonwoven shell is sewn closed. Finished foam insert is exported to the United States. |
| Reason: As the fabric forming the shell of the foam cushion insert is formed in a single country, that is, Vietnam, as per the terms of the tariff shift requirement, country of origin is conferred in Vietnam. |
| Ruling Date: July 3, 2025 |
N350306: The country of origin of an E-bike
| Origin: Cambodia |
| Item: The Flyer Via Pro R E-bike (Model 886). The lithium battery-powered bicycle is equipped with an electric motor and standard bicycle drivetrain components. It has pedal-assist and throttle functionality. All components and material in the manufacturing process were sourced in China. The assembly process takes place in Cambodia and China. Raw aluminum tubes are first extruded in China and then shipped to Cambodia. In Cambodia, the tubes undergo a multiple complex manufacturing process: Precision bending, cutting, and forming; Welding into a complete bicycle frame structure; Heat treatment to strengthen the welded frame; Dimensional adjustments to meet tolerance specifications; Final painting and surface finishing. The completed and painted frame is then exported to China, where it is received by the finished goods assembler. At this facility: Electrical components, including the lithium battery, motor controller, and display, are sourced from local Chinese suppliers; Mechanical parts such as the shifter, brakes, saddle, wheels, and drivetrain are also locally sourced; The assembler performs assembly, component integration, tuning, and final complete packaging of E-bikes for export |
| Reason: The processes that take place in Cambodia substantially transform the individual components sourced from China to complete the E-bikes. These processes are sufficiently complex and meaningful and result in a substantial transformation, such that the non-originating components lose their individual identities and become an integral part of new articles, possessing new names, characters and uses. Therefore, the country of origin for the Flyer Via Pro R E-bike (Model 886) will be Cambodia. |
| Ruling Date: July 3, 2025 |
N350415: The tariff classification of Greeter Standing Bears from China
| HTS: 9503.00.0090, 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… Other.” |
| Item: The items are described as decorative bears. Item 1, in a boy style, is wearing pants, a shirt, and a coat. Item 2, in a girl style, is wearing a skirt, shirt, coat, and bow. The items are made of 85% polyester fabric and 15% plastic. The plastic component is located within the waist, legs, and feet of the bears, to allow them to stand upright. The legs have a telescoping feature that enables their extension and allows the consumer to make the figures taller or shorter, depending on preference. |
| Reason: N/A |
| Ruling Date: July 3, 2025 |
N350507: The country of origin of toilet tissue
| Origin: Indonesia |
| Item: The paper product under consideration is "toilet tissue." They come in either single, double or triple ply rolls. The bulk rolls of toilet tissue stock are manufactured in Indonesia. The paper is White/Kraft 100% wood pulp virgin paper; layer:2; 12.5-14 g/sm. These parent rolls of tissue paper, which measure 2800mm in width and have a maximum roll diameter of 2800mm, are then sent to China, where the paper is unwound, embossed, rewound and cut to size. The toilet tissue is then subjected to quality control and packaged. |
| Reason: In China, the toilet tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by unwinding, embossing, winding, cutting and packaging. |
| Ruling Date: July 3, 2025 |
N350513: The country of origin of napkins
| Origin: Sweden |
| Item: The paper products under consideration are "beverage napkins," "luncheon napkins," and "dinner napkins." They come in either single, double or triple ply with 1/4, 1/6 or 1/8 fold. The bulk rolls of napkin stock are manufactured in Sweden. The paper is White/Kraft 100% wood pulp virgin paper; layer:1-3; 15.5-18 g/sm. These parent rolls of tissue paper, which measure in multiple widths from 300mm up to 860 mm and have a maximum roll diameter of 860mm, 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 Sweden. |
| Ruling Date: July 3, 2025 |
N350591: The tariff classification of a plastic trophy from China
| HTS: 3926.40.0090, 9903.01.24; 9903.01.25, 5.3% + 20% + 10%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [s]tatuettes and other ornamental articles: [o]ther.” |
| Item: The product under consideration is a trophy intended to be presented as an award to recognize an employee’s years of service. At the top is a statuette made of acrylonitrile butadiene styrene (ABS) plastic that is plated to have a golden appearance. It is standing on a pedestal with alternating red and white magnetic discs that are made of acrylic plastic which represent the years of service. Each disc is marked with a number in intervals of five. The “35” disc is larger than the others and is also made of ABS plastic plated to be gold in color. |
| Reason: N/A |
| Ruling Date: July 3, 2025 |
N350718: The tariff classification of wood-frame windows from China
| HTS: 4418.19.0000 (4418.11.0000 if made from tropical wood), 9903.01.24; 9903.01.25; 9903.88.03, 3.2% + 20% + 10% + 25%, “Builders' joinery and carpentry of wood, including cellular wood panels and assembled flooring panels; shingles and shakes: Windows, French-windows and their frames: Other.” |
| Item: The product under consideration is wood-framed windows. The entire framework of the windows is constructed of engineered wood of an unidentified species. The exterior surface of the windows is overlaid with extruded aluminum cladding for weather protection. The full construction and interior surface of the windows is exposed wood. The glass panes are installed in the windows. The windows are for a home renovation and not for commercial sale. |
| Reason: N/A |
| Ruling Date: July 3, 2025 |