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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N349831: Country of origin determination of a changing pad
| Origin: China and Cambodia |
| Item: The “Contour Changing Pad,” which consists of a changing pad and cover. The manufacturing operations are as follows: In China, Polyester nonwoven lining (top and sides) is formed. Polyethylene vinyl acetate (PEVA) (top and sides) is formed. Polyester nonwoven and PEVA are quilted using the pinsonic process. Nonwoven fabric for bottom of cover is formed and coated. (Scenario 2) Fabric(s) is/are exported to Cambodia on rolls. In Cambodia, Polyurethane foam cushion is formed. Non-woven fabric for bottom of cover is formed and coated. (Scenario 1) Strap and buckles are formed. Fabrics are cut and sewn to form the cover. Fabric cover is labelled, straps with buckles are sewn to fabric, zipper is inserted. Fabric cover is packed. Foam cushion insert is cut, bonded, compressed, and packed. Foam cushion and cover are packaged together and exported to the United States. |
| Reason: In scenario 1, as this nonwoven fabric is formed by the fabric-making process in a single country, that is, Cambodia, country of origin is conferred in Cambodia. In scenario 2, as the nonwoven fabric is formed by the fabric-making process in a single country, that is China, country of origin is conferred in China. |
| Ruling Date: July 3, 2025 |
N349871: The country of origin of aluminum wheels
| Origin: China |
| Item: Aluminum wheels used in semi-trailer trucks and trailers. The process of producing the aluminum wheels starts in China, where aluminum bars are cut, ingots undergo heating, forging into a circular shape, and expanding. The product is exported to Thailand, where it undergoes flow forming (stretching the rim to the required size and structure), solution, turning, milling holes, drilling holes, finish turning, deburring, pre-cleaning, burnishing (sanding), polishing inside and outside, applying special coating on the surface of workpiece to prevent oxidation corrosion, removing polishing paste, loading valve, marking, testing, and packaging. |
| Reason: The processes in Thailand do not transform the Chinese product into a new and different article, having a distinct name, character, or use. The product as imported from China has the shape and character of the wheel, and the use of the product is predetermined. As a result, no substantial transformation occurs in Thailand, and the country of origin of the aluminum wheels is China. |
| Ruling Date: July 3, 2025 |
N349949: The country of origin of steel door hinges
| Origin: Malaysia |
| Item: Steel door hinges made of steel with grade of 1008 or stainless steel of grade SUS304 and produced to the ANSI/BHMA A156.1 standard. At the time of importation, the completed hinges and required number of mounting screws are packed in the same master-carton. All the components of the hinge -- the leaves, pin, and mounting screws -- are sourced or manufactured in Malaysia and then exported to China to be plated, powder-coated, or painted into different finishes; assembled; and packed with the required number of screws into one master carton for export to the United States. The raw steel is sourced, cold-rolled into flat sheets, cut into strips, die-cut and roll-formed into the leaves of a hinge in Malaysia. The die and mould are made to specifications to have the desired size, corners, screw-hole location, screw hole diameters, etc. |
| Reason: The plating, powder coating, or painting, and the simple assembly of the Malaysian components in China do not result in a substantial transformation. As such, the country of origin for these subject hinges would be Malaysia. |
| Ruling Date: July 3, 2025 |
N349950: The country of origin of steel door hinges
| Origin: Thailand |
| Item: Steel door hinges made of steel with grade of 1008 or stainless steel of grade SUS304 and produced to the ANSI/BHMA A156.1 standard. At the time of importation, the completed hinges and required number of mounting screws are packed in the same master-carton. All the components of the hinge - the leaves, pin, and mounting screws are sourced or manufactured in Thailand and then exported to China to be plated, powder-coated, or painted into different finishes; assembled; and packed with the required number of screws into one master carton for export to the United States. The raw steel is sourced, cold-rolled into flat sheets, cut into strips, die-cut and roll-formed into the leaves of a hinge in Thailand. The die and mould are made to specifications to have the desired size, corners, screw-hole location, screw hole diameters, etc. |
| Reason: The plating, powder coating, or painting, and the simple assembly of the Thai components in China do not result in a substantial transformation. As such, the country of origin for these subject hinges would be Thailand. |
| Ruling Date: July 3, 2025 |
N349979: The tariff classification of one-piece molded flip flops and slides from China
| HTS: 6402.99.2760, 9903.01.24, 9903.01.25, 3% + 20% + 10%, “Footwear with outer soles and uppers of rubber or plastics: other footwear: having uppers of which over 90 percent of the external surface area (including any accessories or reinforcements) is rubber or plastics (except footwear having a foxing or a foxing-like band applied or molded at the sole and overlapping the upper and except footwear designed to be worn over, or in lieu of, other footwear as a protection against water, oil, grease or chemicals or cold or inclement weather): other: sandals and similar footwear of plastics, produced in one piece by molding, for women.” |
| Item: The Pure Stride Flip Flops for Plantar Fasciitis and the Pure Stride Slides for Plantar Fasciitis are one-piece molded footwear consisting of ethyl vinyl acetate (EVA) rubber or plastics. The outsole unit portions of the unisex flip-flops and slides have deep heel seats and are contoured for enhanced arch support and metatarsal rise to take the stress off the plantar fascia ligament. These items were designed to help people to walk without severe pain from plantar fasciitis. Both styles of sandals are not designed to cure any physical abnormalities or conditions. Both styles are available for retail sale in pairs and in a range of sizes in physician offices, pedorthic stores, and to the general population on various internet websites. |
| Reason: The Pure Stride Flip Flops for Plantar Fasciitis and the Pure Stride Slides for Plantar Fasciitis do not satisfy the five factors or duty-free treatment under subheading 9817.00.96 as set out by CBP. Both styles are not distinguishable by design or form from articles useful to non-handicapped people. They are not imported with any extraordinary construction features that signal they are for use by handicapped people and not useful to the general public. A secondary classification in subheading 9817.00.96 will not apply. |
| Ruling Date: July 3, 2025 |
N349992: The country of origin and marking of a monitor
| Origin: Vietnam and China |
| Item: A Liquid Crystal Display LCD monitor which has a viewable area of 27 inches and has video connectivity with Display Port, HDMI and VGA. In scenario 1, the interface board, the joystick board, and the USB board are manufactured via surface mount technology (SMT) and dual in line package (DIP) processes in Vietnam. The interface board controls the thin film transistor (TFT) panel and includes a layer of technology for the low-voltage differential signaling (LVDS), which is added to the board through the SMT process in Vietnam. In addition, the Taiwanese scaler unit, which includes low-voltage differential signaling, a timing control unit, and converts and processes automatic data processing (ADP) and video signals, is assembled onto the interface board by the SMT process in Vietnam. Further, the driver board is combined with the power board through the SMT and DIP processes in Vietnam. All three printed circuit assemblies (PCBAs) are fully assembled in Vietnam and then shipped to China. Regarding this first scenario, all other components, including the LCD panel, are manufactured in China. The final assembly process takes place in China, which includes plugging, snapping, inserting, pressing, affixing, etc., the components together. In scenario 2, the manufacturing process starts with the production of the LCD panel in Korea, which is shipped to China for final assembly with other components manufactured in China. In this case, the country of manufacturing for all PCBAs, including the interface board, joystick board, USB board, driver board, and power board through Surface Mount Technology (SMT) and Dual in Line Package (DIP) processes, are done in China. |
| Reason: The origin of this monitor is the country in which the underlying PCBAs are produced. Hence, the PCBAs impart the prominent character of the device since it performs the primary and vital functions of the monitor, which is forming images for display. In this case, the PCBAs are made in either Vietnam or China, depending on the scenario. Regarding scenario 1, the assembly process performed in China would not substantially transform the PCBAs into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, the country of origin of the subject monitor in the first scenario is Vietnam and in the second scenario is China. |
| Ruling Date: July 3, 2025 |
N350043: The tariff classification of an OLED monitor from South Korea
| HTS: 8528.52.000, 9903.01.32, free, “Monitors and projectors not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other monitors: Capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471.” |
| Item: The merchandise under consideration is a 55-inch transparent OLED monitor, which contains an embedded controller board, which converts and processes video and ADP signals. It can directly connect to an ADP machine via its HDMI and/or display port (DP) connectors and is designed to be used with an ADP machine. Moreover, the self-emissive display, which is bonded with tempered glass, provides transparency. |
| Reason: N/A |
| Ruling Date: July 3, 2025 |
N350055: Country of origin determination for a comforter
| Origin: Pakistan |
| Item: The “Blossom Trail Comforter Green Tea” is a reversible quilted comforter made with an outer shell of 100% cotton woven fabric. The face and back panel fabrics are both dyed and printed with the same botanical design. The fabric has also been subject to bleaching and shrinking. The comforter is stuffed with 100% polyester batting and the three layers are quilted together. The manufacturing operations for the comforter are as follows: In Pakistan, cotton greige fabric is woven. Cotton greige fabric is shipped in rolls to China. In China, cotton fabric is bleached, shrunk, dyed, and printed. Batting, piping and sewing thread is formed. Fabrics are cut, assembled by sewing, and quilted. Finished reversible quilted comforter is packaged and shipped to the United States. |
| Reason: The fabric making process of the comforter's outer shell constitutes the most important manufacturing process. It is the outer shell which actually forms the merchandise. Accordingly, the fabric making process in Pakistan, where the fabric for the comforter's outer shell is formed, constitutes the most important manufacturing process. Therefore, the country of origin of the subject comforter is Pakistan. |
| Ruling Date: July 3, 2025 |
N350112: The country of origin of a vinyl record
| Origin: China |
| Item: A vinyl record, which is a circular, flat disc made of polyvinyl chloride (PVC) resin, with a label affixed to the center of the disc. The surface of the disc contains spiral-shaped, microscopic grooves. The audio content is created and digitally recorded in a studio in the Republic of Korea, which includes creating the lyrics and melody. The physical vinyl record (medium), which enables analog sound playback via spiral audio grooves, is fully manufactured in China. This process starts with a lacquer cutting process, where a special needle precisely engraves minute grooves onto a lacquer-coated disc, following the vibrations of the audio signal derived from the received online audio file. This lacquer disc is the original vinyl record. The next step consists of the stamper production, which serves as a mold to imprint grooves onto both sides of the vinyl record. Once the album is fully produced in China, it is wrapped in plastic film and then shipped to the Republic of Korea for the final inspections, including functionality and appearance checks. |
| Reason: The subject vinyl record is fully manufactured in China. No manufacturing processes are being performed in South Korea. Accordingly, the country of origin of the finished records will be China. |
| Ruling Date: July 3, 2025 |
N350114: The tariff classification of a personal assistant robot from Vietnam
| HTS: 8543.70.9860, 9903.01.25, 2.6% + 10%: “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” |
| Item: The Ballie robot, which is an advanced, artificial intelligence (AI) driven personal assistant. The subject robot is a small, spherical device that incorporates wheels, allowing it to move around a room. The device further incorporates various cameras, a projector, Infrared (IR) sensors, a microphone, speaker, LiDar, as well as various environmental sensors. The only mechanical properties of the device are the wheels, and it does not incorporate any arms or other articulating features. In use, the robot acts as a rolling companion and AI personal assistant for home automation, allowing users to control various smart appliances, lights and other connected devices throughout the home. The robot connects to the internet and other devices throughout the home via WiFi and Bluetooth. The user can verbally communicate with the robot, speaking commands, to which the device will respond by using a large language model search. The cameras and projector allow for the device to monitor the surrounding area as well as to project information including streaming videos and other content on any wall throughout the home. |
| Reason: N/A |
| Ruling Date: July 3, 2025 |