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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N350116: The tariff classification of battery packs from China
| HTS: 8507.60.0020, 9903.01.24; 9903.01.25; 9903.88.15, 3.4% + 20% + 10% + 7.5%, “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Lithium-ion batteries: Other.” |
| Item: The first item under consideration is referred to as the Enouvation E5 power pack, and is described as a battery pack for power motion recliners, reclining sofas, or loveseats. It consists of lithium-ion pouch cells encased in a plastic housing with an LED indicator, a manual power switch, a cable with a barrel jack input connector, and a cable with a two-pin output connector. The power pack has a nominal voltage of 25.9 VDC, a nominal capacity of 5,000 mAh, and a nominal energy of 129.5 Wh. The second item under consideration is referred to as the Enouvation E10 power pack, and is described as a battery pack for power motion sectionals. It consists of lithium-ion pouch cells encased in a plastic housing with an LED indicator, a manual power switch, a cable with a barrel jack input connector, and a cable with a two-pin output connector. The power pack has a nominal voltage of 25.9 VDC, a nominal capacity of 10,000 mAh, and a nominal energy of 259 Wh. |
| Reason: N/A |
| Ruling Date: July 7, 2025 |
N350166: The country of origin of a multimeter
| Origin: Vietnam |
| Item: The SDT-830C handheld digital multimeter, which is an electronic instrument that measures AC/DC voltage, current, and resistance. In operation, the user selects the desired measurement function (voltage, current, resistance, etc.) using the rotary dial on the multimeter. The SDT-830C is made of a printed circuit board assembly (PCBA), LCD display, rotary selector switch, input and output jacks, and a molded plastic housing. Once fully assembled, the device is used by electricians and technicians for precision electrical measurements. In Vietnam, the PCBA is constructed using surface-mount technology (SMT). The process involves placing and soldering hundreds of various components onto the printed circuit board (PCB). Bare semiconductor dies are bonded and wire-connected under epoxy encapsulation, and larger through-hole parts are hand-inserted and soldered. Once complete, the software programs are uploaded to the PCBA boards, which are then functionally tested. The completed Vietnamese PCBA is then shipped to China where it is installed into a Chinese-origin plastic housing. Additional Chinese components, including the LCD displays, selector knobs, and connectors are also installed at this time. Finally, silk printing is performed on the final product before packaging and shipping to the United States. |
| Reason: The creation of the PCBA in Vietnam using SMT generates a working PCBA capable of performing measurements. The incorporation of the PCBA into the plastic housing and adding the dial and LCD screen in China does not change the end use of the PCBA. The multimeter’s core functionalities are firmly established in Vietnam during the circuit board assembly and programming stages and are only enhanced for cosmetic and protective purposes in China. |
| Ruling Date: July 7, 2025 |
N350320: The country of origin of an air temperature sensor
| Origin: Japan |
| Item: The item under consideration is described as an Intake Air Temperature Sensor, which is attached to the intake pipe inside an automobile’s engine bay. Japanese components include the thermistor (sensor that converts temperature to a specific resistance value), lead wires (connect the thermistors to the terminals), terminals (connect the thermistor’s electrical output to the automobile) and resin for the manufacture of the cap and molded parts. The Chinese components include an O-ring (provides the sensor with an air seal), collar (brass component which affixes the Air Temperature Sensor to the automobile), tube (provides insulation between the lead wires), cap (plastic component that protects the thermistor made from Japanese resin) and additional molded parts (maintain air tightness of the finished sensor and also made with Japanese resin). The Thermistor chip is manufactured in Japan through a multi-step ceramic materials process. In China, the fully finished thermistor chip with lead wires is connected to terminals via a welding process. Molded plastic parts are created through injection molding which are then combined with the finished thermistor with lead wires and terminals through insert molding to create a finished Air Temperature Sensor. |
| Reason: The addition of the Chinese O-ring, collar, tube, cap, and molded parts do not substantially transform the completed Japanese thermistor, which provides the sensor the ability to measure temperature. The thermistor chip can only be used with the Air Temperature Sensor when it leaves Japan and is predominately encapsulated in plastic for air sealing and protection purposes. |
| Ruling Date: July 7, 2025 |
N350371: The tariff classification of crutches from China
| HTS: 9021.10.0090, 9903.01.24; 9903.01.25, free + 20% + 10%, “[o]rthopedic appliances, including crutches, surgical belts; splints and other fracture appliances …[o]rthopedic and fracture appliances, and parts and accessories thereof: [o]ther.” |
| Item: In-Motion forearm and underarm metal crutches. The crutches are spring assisted, ergonomically designed crutches. The forearm crutches have a cuff that fits around the forearm and a handgrip. The underarm crutches have an underarm cradle that rest under the armpit and a handgrip. The crutches are packaged and sold in pairs. |
| Reason: N/A |
| Ruling Date: July 7, 2025 |
N350490: The tariff classification of a countermeasure dispenser and a pylon from Sweden
| HTS: (countermeasure dispenser) 9301.90.9090, 9903.01.25, free + 10%, “Military weapons, other than revolvers, pistols and the arms of heading 9307: Other: Other: Other.” (P2/3 Pylon) 8807.30.0060, 9903.85.08; 9903.01.25, free + 10% + 50%, “Parts of goods of heading 8801, 8802 or 8806: Other parts of airplanes, helicopters or unmanned aircraft: Other.” |
| Item: The first item under consideration is described as an electromechanical countermeasure dispenser for dispensing chaff and infrared expendables from military aircraft. Once incorporated, the dispenser discharges chaff and expendables to disrupt and defeat enemy infrared or radio frequency guided threats. It can be fitted to all fixed wing platforms and installed into other components such as missile launchers, conformal housings, pylons, fuselage or external pods. The second article under consideration is described as a P2/3 Pylon, which attaches to the underwing of an aircraft. The pylon is composed of steel, stainless steel, and aluminum, and is designed to hold fuel tanks, air-to ground weapons, and air-to air weapons. |
| Reason: N/A |
| Ruling Date: July 7, 2025 |
N350566: The tariff classification of a fabric snowman 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: A decorative snowman wearing a coat, hat, and scarf. It is made of polyester and comes in two different color styles. |
| Reason: N/A |
| Ruling Date: July 7, 2025 |
N350583: The tariff classification of a foam block set from China
| 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: A foam block set. It includes 50 blocks of various shapes, sizes, and colors packaged together in a plastic case. Children can use the blocks to build, stimulating imaginative play. The item is recommended for children ages 3 and older. |
| Reason: N/A |
| Ruling Date: July 7, 2025 |
N350796: The country of origin of drywall corner tools and a tape knife
| Origin: Vietnam |
| Item: The items under consideration are drywall corner tools and a tape knife. The steel blades are attached to steel handles with polypropylene and thermoplastic rubber grips. The manufacturing process for the drywall corner tools begins in Vietnam, where stainless steel is die cut into the rectangular and trapezoidal flat shapes of the blades. The blades are also stamped into their final angled forms before being sent to China. In China, each blade is welded together with a steel connection part and a Chinese-origin cold forged steel handle. Finally, polypropylene and thermoplastic rubber are applied to the steel handles in China. There are two manufacturing scenarios for the taping knife: Scenario one: In Vietnam, stainless steel is die cut into flat trapezoidal shapes, which is the final size and shape of each blade. The blades are then sent to China where each is pressed together with a Chinese-origin aluminum rigid black plate. Holes are punched through the back plate and blade, and a polypropylene and thermoplastic rubber handle is attached. Finally, a zinc alloy hammer end is attached to the end of the handle. Scenario two: This scenario is the same as the first, except the aluminum rigid back plates are manufactured in Vietnam. The blades and back plates are then sent to China where they are pressed together. Holes are punched through the back plate and blade, and a polypropylene and thermoplastic rubber handle is attached. Finally, a zinc alloy hammer end is attached to the end of the handle. |
| Reason: It is the blade of each tool that contributes to the main functionality of each of the finished tools. Based on the assembly operations performed in China, the blade is not substantially changed so as to transform it into a new article with a different name, character, or use. |
| Ruling Date: July 7, 2025 |
N350909: The tariff classification of a Halloween decoration from China
| HTS: 9505.90.6000, 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: Other: Other.” |
| Item: An item identified as Light Up Eyes with Moving Pupil for Halloween Decoration, which consists of a pair of plastic light up eyes with moving black pupils. The eyes measure approximately 12” in diameter each and have an approximately 50’ cord with an adapter that plugs into a power source. The moving eyes provide an eerie atmosphere for the home. The eyes are marketed and sold as a Halloween decoration. |
| Reason: N/A |
| Ruling Date: July 7, 2025 |
N349794: The tariff classification of two steel soaking tubs from the United Kingdom
| HTS: 7324.29.0000, 9903.81.97; 9903.01.25, free + 10% + 25%, “Sanitary ware and parts thereof, of iron of steel: Baths: Other.” |
| Item: The first article under consideration is described as a Wood-Fired Stainless Steel Water Heating and Soaking System. It is a fully insulated stainless steel tub with a fixed internal heating system. This freestanding outdoor soaking tub is made of 316/304 stainless steel. The water in the tub is heated via an internal, fixed wood-burning combustion chamber. The second article under consideration is described as an Electric Stainless Steel Water Heating and Soaking System. It is a fully insulated stainless steel tub with a fixed internal heating system. This freestanding outdoor soaking tub is made of 316/304 stainless steel. |
| Reason: N/A |
| Ruling Date: July 3, 2025 |