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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N350189: The tariff classification of two carbon slurry products from Japan
| HTS: 3824.99.9397, 9903.01.32, 5%, “Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Other: Other: Other: Other.” |
| Item: Two carbon slurry products with the product numbers BP-1700, and BP-1754US. They are combinations of 1-Methyl-2-pyrrolidone, and carbon black. Subsequent to their importation into the United States they will be used on cathode electrodes in lithium-ion batteries to facilitate electron conductivity. |
| Reason: N/A |
| Ruling Date: July 8, 2025 |
N350205: The tariff classification of two roofing underlayment materials from India
| HTS: 5903.90.3090, 9903.01.25, 2.7% + 10%, “Textile fabrics impregnated, coated, covered or laminated with plastics, other than those of heading 5902: Other: Other… Other.” |
| Item: Roofing underlayment materials which contain three primary layers, consisting of nonwoven fabric, aluminum foil, and laminated textile fabric (scrim) with coating. The layers of lamination and the coating materials are all said to be composed of polyethylene type plastic. The aluminum foil layer will act as a fire protective layer to enable the underlayment to pass burn testing more consistently than an underlayment without the aluminum foil. |
| Reason: N/A |
| Ruling Date: July 8, 2025 |
N350270: The tariff classification of a card holder from Italy
| 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: The product under consideration is a card holder. The card holder’s exterior shell is made with grooved aluminum to match RIMOWA's original travel goods collection. The interior compartment is made of rigid plastic and rotates in and out of the shell on an articulated pivot. It will come in three colors, silver, black, and titanium. |
| Reason: N/A |
| Ruling Date: July 8, 2025 |
N350345: The country of origin of an oil filter
| Origin: Thailand |
| Item: Oil filters assembled in Thailand using components from Thailand and China. The Thai components include the spray shell assembly, shell, hot dip galvanized sheet, black powder, oil filter element assembly, central tube, origami (pleating or folding of the filter paper to increase its surface area for more efficient filtration), screw fit plate assembly, threaded cover plate, and some of the packaging including corner protectors, tray cover, pallet, and outer box. The Chinese components include the upper-end cover, adhesive, galvanized thin sheet, filter paper, lower end cover assembly, diaphragm, silicone rubber, sealing plate, toothless cover plate, sealing ring, and some of the packing including the color box, labels and dust film. The assembly process occurs in Thailand and includes thirty-four individual steps. |
| Reason: The manufacturing and assembly process performed in Thailand is considered complex. Numerous steps are needed to transform the individual components from China into a finished oil filter in Thailand. The individual components each have a change in name, character, and use. Therefore, the country of origin of the oil filter is Thailand, which is where the assembly process occurs, half the components are manufactured, and the Chinese components are transformed into a finished oil filter. |
| Ruling Date: July 8, 2025 |
N350390: The tariff classification of liquid chromatography columns from Japan
| HTS: 8421.29.0065, 9903.01.25, free + 10%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: Other: Other: Other: Other.” |
| Item: Eicom High-Performance Liquid Chromatography (HPLC) columns, which are designed to separate molecules based on their chemical properties and then detect the separate molecules using electrochemical reactions. The columns contain a stationary phase that interacts with the sample components, while the mobile phase carries the sample through the column. Eicom systems are known for their high sensitivity and are frequently used in neuroscience research for neurotransmitter detection. |
| Reason: N/A |
| Ruling Date: July 8, 2025 |
N350516: The country of origin of toilet seat covers
| Origin: Indonesia |
| Item: The paper products under consideration are toilet seat covers. The bulk rolls of toilet seat cover tissue are manufactured in Indonesia. The toilet seat covers are white/kraft paper: virgin; layer: 1;14 g/sm. These parent rolls of toilet seat cover tissue, which measure 360mm in width and have a maximum roll diameter 360mm, are then sent to China, where the tissue paper is embossed, folded, cut to size and sometimes octagonal shape, subjected to quality control, and packaged. |
| Reason: In China the tissue paper does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, folding, cutting, and packaging. The tissue paper is specifically dedicated for use as toilet seat covers and does not change into a new and different product by its working. |
| Ruling Date: July 8, 2025 |
N350709: The country of origin of cold-rolled stainless steel sheet
| HTS: 7219.90.0080, 9903.81.87; 9903.01.33, free + 50%, “Flat-rolled products of stainless steel, of a width of 600 mm or more: Other: Other: Other: Other.” |
| Origin: Taiwan |
| Item: The product to be imported is a polished and coated Grade 430 stainless steel sheet. This cold-rolled, cut-to-length sheet measures 0.9 mm in thickness, 1219 mm in width, and 3048 mm in length. A polyvinyl chloride (PVC) coating is applied to protect the surface finish. The sheet is made to ASTM A240 and will be used in the production of end-use products such as appliances or outdoor grills. The stainless steel slab is hot-rolled, annealed, and pickled in China. The product is a 430 Grade stainless steel hot-rolled coil measuring 3.0 mm in thickness and 1219 mm in width. This hot-rolled steel coil is shipped to Taiwan and undergoes cold-rolling, pickling, bright annealing to a 2B mill finish, skin passing, and tension leveling. Next, the coil is polished, slit into sheets, and a PVC coating is applied to one side, and an anti-fingerprint coating is applied to the opposite side. The final product measures 0.9 mm in thickness and1219 mm in width. Lastly, the sheets are cut-to-length and then packaged for export. |
| Reason: The manufacturing operations performed in Taiwan, such as cold-rolling, result in a substantial transformation. Accordingly, the country of origin of the stainless steel sheet will be Taiwan. |
| Ruling Date: July 8, 2025 |
N349974: The tariff classification of a powder from China
| HTS: 3824.99.3990, 9903.01.24; 9903.01.25; 9903.88.03, free + 20% + 10% + 25%, “Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Mixtures of two or more inorganic compounds: Other: Other.” |
| Item: The item in question has the product name “Zirconium Oxide HWY 5.5 Powder.” It comprises various inorganic compounds and upon importation the powder will be used in the fabrication of dental discs and to make prosthetic teeth and bridges. |
| Reason: N/A |
| Ruling Date: July 7, 2025 |
N350045: The tariff classification of steel grab bars from China
| HTS: 8302.41.6080, 9817.00.96, free, “Base metal mountings, fittings and similar articles… Other mountings, fittings, and similar articles, and parts thereof: Suitable for buildings: Other: Of iron or steel, of aluminum or of zinc… Other.” |
| Item: The articles under consideration are described as Basic Grab Bars and Designer Grab Bars. These grab bars are made of stainless steel, measure 1.5 inches in diameter, have weight-load bearing capacities of 250 to 500 pounds, a wall spacing of 1.5 inches, and meet or exceed ADA standards. They can be installed using screws if correct stud anchoring exists at the installation location. The marketing and product specification sheet informs consumers that the bar meets ADA standards and displays the graphic symbol of a handicapped person. The designer grab bars come in either curved or straight configurations and include grip pads. These grab bars will be sold to large-scale medical and rehabilitation providers. |
| Reason: The Basic Grab Bars and Designer Grab Bars satisfy the 5 factors set out by CBP. As a result, a secondary classification will apply in subheading 9817.00.96. |
| Ruling Date: July 7, 2025 |
N350059: The country of origin of an oven latch assembly from China
| Origin: China |
| Item: The product under consideration is an oven latch assembly used in a gas range where the oven door is closed manually but locked by oven latch. It is powered and controlled by the main board from the gas range to lock and unlock the oven door. The oven latch assembly consists of a latch, pin, rod, power driver containing an electric motor, screw and four metal brackets in different shapes. All of the components are of Chinese origin and assembled into the finished oven latch assembly in Thailand. The assembly process in Thailand is described as follows: Riveting components with the metal brackets; Installing the latch; Installing the rod; Riveting components with the metal bracket; and Installing the power driver Test and package. |
| Reason: All the components of the oven latch assembly are of Chinese origin. The components are imported into Thailand where they are assembled into the finished oven latch assembly. The components do not undergo a physical change, nor do they change in character as a result of the assembly operations in Thailand. The components have a pre-determined end-use as parts and components of the oven latch assembly at the time of importation into Thailand and do not undergo a change in use due to the assembly process in Thailand. Accordingly, the nature of the assembly process for the oven latch assembly in Thailand is not sufficiently complex or meaningful as to constitute a substantial transformation. |
| Ruling Date: July 7, 2025 |