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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N350766: The country of origin of a four-way crimp tool
| Origin: Vietnam |
| Item: A four-way crimp tool designed to secure electrical connectors onto wires by deforming the connector around the wire. It consists of two hinged handles and two round jaws that each incorporate a round hole. The jaws are assembled, one inside the other, with four steel cam-actuated indenters. The manufacturing process for the 4-way crimp tool begins in Vietnam, where carbon steel is forged into the final size and shape of the left handle and jaw. Also in Vietnam, the right handle and jaw is cut from steel and formed into its final size and shape. These two pieces are then sent to China, where they undergo precision milling and surface treatment, and a PVC grip is applied to each handle. Finally, the jaws and handles are assembled, one inside the other, with springs, rivets and four steel cam-actuated indenters. |
| Reason: A substantial transformation occurs in Vietnam. It is here that steel is cut, formed and forged into the final size and shape of the left and right jaws and handles of the tool. It is these components that contribute to the main functionality of the finished tool. |
| Ruling Date: July 9, 2025 |
N350881: The tariff classification of butadiene, methyl methacrylate, styrene copolymers from the Netherlands
| HTS: 3902.90.0050, 9903.01.32, 6.5%, “polymers of propylene or of other olefins, in primary forms: Other: Other.” |
| Item: Clearstrength E920 is a core-shell impact modifier and is a butadiene, methyl methacrylate, styrene copolymer. It is composed of 85% butadiene, 10% methyl methacrylate and 5% styrene. It is designed to provide excellent ambient and low temperature toughness as well as maximum impact to polycarbonate, polyesters and a variety of polycarbonate blends. The product is imported in the form of white powder or pellets. It is recommended for use in automotive applications, electrical and electronic components and polycarbonate parts. Clearstrength C303H is described as a core-shell impact modifier and is a butadiene, methyl methacrylate, styrene copolymer. It is composed of 65% butadiene, 8% methyl methacrylate and 27% styrene. It is designed to provide impact strength and transparency to polyvinyl chloride (PVC) film and sheets. The product is imported in the form of white powder. It is recommended for use in high quality PVC films, sheets and bottles. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N342179: The tariff classification of yarns from Turkey
| HTS: Items (1), (3) 5404.90.0000, 9903.01.25, free + 10%, “Synthetic monofilament of 67 decitex or more and of which no cross-sectional dimension exceeds 1mm; strip and the like (for example, artificial straw) of synthetic textile materials of an apparent width not exceeding 5 mm: Other.” Items (2), (4) 5607.49.1500, 9903.01.25, 7% + 10%, “Twine, cordage, rope and cables, whether or not plaited or braided and whether or not impregnated, coated, covered or sheathed with rubber or plastics: Of polyethylene or polypropylene: Other: Other, not braided or plaited: Measuring less than 4.8 mm in diameter.” |
| Item: Item (1) is described as a fibrillated yarn, composed of either 100% polypropylene fibrillated filament strip or 100% polyethylene fibrillated filament strip. It may have a linear density of either 7,500 or 2,200 decitex, depending on the color. The yarn does not exceed 5 millimeters (mm) in width. Item (2) is described as “monofilament straight yarn.” The yarn is a 6-ply 100% polyethylene filament yarn measuring 13,300 decitex. Item (3) is described “monofilament textured curly yarn.” The yarn is an 8-ply monofilament yarn composed of either polypropylene or polyethylene and has a linear density of 5,555 decitex. Item (4) is described as a “monofilament combination yarn” in which 8-plies of straight monofilament yarns are twisted together with 8-plies of curly yarns. The 16-ply yarn is composed from either polypropylene or polyethylene and has a linear density of 10,300 decitex. |
| Reason: N/A |
| Ruling Date: July 8, 2025 |
N349967: The tariff classification of footwear inserts from China
| HTS: 6406.90.3060, 9903.01.24, 9903.01.25, 5.3% + 20% + 10%, “Parts of footwear; other: removable insoles, heel cushions and similar articles; of rubber or plastics; other.” |
| Item: The five imported items are multi-layered footwear inserts that are designed to help relieve foot pain including plantar fasciitis, heel pain and metatarsalgia. The Pre Fab Diabetic Inserts are unisex footwear inserts or insoles available in twelve sizes. They are said to consist of two layers of 100% EVA rubber/plastics. The top layer is less hard than the bottom layer. The Pure Stride Full Length Orthotics, the Pure Stride Full Length RX PU Orthotics, the Pure Stride Full Length RX MF Orthotics, and the Pure Stride Full Length Bold Orthotics are footwear inserts comprised of four layers of material. Each has a top layer consisting of anti-microbial mesh. The second layer of the Full Length Orthotics and the Full Length Bold Orthotics consists of a soft EVA rubber/plastics. The second layer of the Full Length RX PU Orthotics consists of a polyurethane foam, and the second layer of the Full Length RX MF Orthotics consists of memory foam. All styles have a contoured polypropylene shell as a third layer and a hard (high durometer) EVA fourth layer. These items 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: N/A |
| Ruling Date: July 8, 2025 |
N349986: The tariff classification of footwear inserts from China
| HTS: 6406.90.3060, 9903.01.24, 9903.01.25, 5.3% + 20% + 10%, “parts of footwear; other: removable insoles, heel cushions and similar articles; of rubber or plastics; other.” |
| Item: Multi-layered footwear inserts that are designed to help relieve foot pain including plantar fasciitis, heel pain and metatarsalgia. The Pure Stride Ultra Orthotics are unisex footwear inserts or insoles available in twelve sizes. They are said to consist of four layers. The first layer is an anti-microbial mesh, the second layer is a polyurethane foam, the third is a heat-moldable PET, a thermoplastic polymer resin shell, and the fourth is a high durometer EVA (rubber/plastics) layer. The Pure Stride Court Orthotics is unisex and available in twelve sizes. The first layer is an anti-microbial vegan leather, the second is identified as Diacell. The third is a PET shell and the fourth layer is a PU (rubber/plastics) material. The Pure Stride Golf Orthotics are unisex and available in twelve sizes. Its layers consist of an anti-microbial vegan leather, a PET layer, and a mix of a high durometer EVA and a material identified as Poron, an open-cell urethane foam. The Pure Stride Kids Orthotics are unisex and available in eight sizes. The first layer is an anti-microbial mesh. The second layer is a heat moldable EVA. The third layer is a polypropylene shell, and the fourth layer is a high durometer EVA. The Pure Stride Men's Dress Orthotics are men's footwear inserts available in seven sizes. The first layer is anti-microbial vegan leather. The second layer is an open cell foam. The third layer is a PET shell, and the 4th layer is a micro suede base layer. |
| Reason: It is the rubber or plastics layers that provide the essential character to each of the items for classification purposes. |
| Ruling Date: July 8, 2025 |
N349999: Country of origin determination for sheets, duvet cover, and pillowcases
| Origin: Pakistan |
| Item: The subject merchandise, described as “Blossom Trail Percale Green Tea,” includes a flat sheet; fitted sheet; pillowcases; and a duvet cover. All of the items are made of 100% cotton woven fabric that is both dyed and printed with a botanical print design of stems and flowers. The manufacturing operations for the sheets, duvet cover, and pillowcases, 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, dyed, printed and shrunk. Elastic band, buttons and sewing thread are produced. Fabric is cut, assembled and sewn into finished flat sheets, fitted sheets, duvet covers and pillowcases. Finished sheets, duvet covers and pillowcases are packaged and shipped to the United States. |
| Reason: As the fabrics comprising the sheets, duvet covers and pillowcases are formed in a single country, which is, Pakistan, the country of origin is conferred in Pakistan. |
| Ruling Date: July 8, 2025 |
N350026: The tariff classification, country of origin, and marking of a silver bracelet from the United States
| HTS: 7113.11.5000, 9802.00.5060, 5%, “Articles of jewelry and parts thereof, of precious metal or of metal clad with precious metal: Of precious metal whether or not plated or clad with precious metal: Of silver, whether or not plated or clad with other precious metal: Other: Other.” |
| Origin: U.S. |
| Item: A bracelet made of sterling silver. The bracelet is valued over $18 per dozen. The following manufacturing steps will take place in the United States: Molten silver is poured continuously into a mold and solidified while withdrawn from the bottom. A silver rod or wire is pulled through a die. As it passes through, the diameter is reduced, and the length increases. Multiple passes through progressively smaller dies may be needed to reach the desired thickness. The wires are then made into spools and loaded into a specialized cable twisting machine. After the silver wire has been twisted into a core-supported cable configuration, the entire twisted wire spool is formed into the final bangle geometry. The wire is then uniformly coiled. Once in its final form, the entire assembly undergoes the annealing process to restore the silver’s original malleability. The annealed coil is subjected to a precision sawing operation. This step segments the coil into uniform, rounded individual components using a fine-toothed saw blade, ensuring clean edges and dimensional accuracy for subsequent processing or assembly. The components are processed in a tumbling machine to enhance brightness and remove residual oxides or burs from previous operations. The following manufacturing steps will take place in India: A wax model of the end caps will be created. Following the output from the lost wax casting process, the end caps undergo a filing and polishing sequence before being attached to the bangles. The bangles are submerged in a controlled oxidation bath and then polished. Each article is stamped with a metal mark and/or any other special logo upon request is lasered on the jewelry pieces. The finished bracelet is shipped to the U.S. |
| Reason: The described foreign processing is acceptable for the purposes of subheading 9802.00.5060. Accordingly, upon reimportation, the bracelet will be eligible for tariff treatment under 9802.00.5060, HTSUS, provided the documentary requirements of 19 CFR 10.8 are satisfied. The casting of the bracelet in the United States provides the essence of the finished product. The addition of the end caps and polishing do not substantially transform the casting. As a result, the country of origin of the bracelet is the U.S. |
| Ruling Date: July 8, 2025 |
N350058: The country of origin of an oven spark plug assembly from China
| Origin: China |
| Item: The oven spark plug assembly consists of four “spark plugs” of similar construction but identified with different length and color bundled together. Each oven spark plug consists of a connector, terminal, and “ceramic” attached to an electric wire. The oven spark plug assembly is used in a gas range with a burner and spark module to ignite the gas. All the components are of Chinese origin and assembled into the finished oven spark plug assembly in Thailand. The assembly process in Thailand is described as follows: assembling the electric wire and the terminal, gluing the ceramic, cutting the ignition head, polishing. |
| Reason: All the components of the oven spark plug assembly are of Chinese origin. The components are imported into Thailand where they are assembled into the finished product. The components do not undergo a physical change, nor do they change in character as a result of the assembly operations in Thailand. |
| Ruling Date: July 8, 2025 |
N350085: The country of origin of a tub light from China
| Origin: Thailand |
| Item: A tub light consisting of a printed circuit board assembly (PCBA), lens, lamp base, PVC sealing, an O ring and harness. The PCBA is made via surface mount technology (SMT) in China where it is populated with an LED from South Korea. The tub light is to be used inside of a dryer or washing machine. The light will go on/off when the door is open/closed. All the components are of Chinese origin and assembled into the finished tub light in Thailand. The assembly process in Thailand is described as follows: Assembling the lens with the O ring; Assembling the PCBA to the lamp base; Assembling the harness (connecting the wires with the plug and the light head); Sealing; Testing. |
| Reason: All the components of the tub light are of Chinese origin. The components are imported into Thailand where they are assembled into the finished product. The components do not undergo a physical change, nor do they change in character as a result of the assembly operations in Thailand. Therefore, the country of origin is Thailand. |
| Ruling Date: July 8, 2025 |
N350180: The tariff classification of an electroplastic netting fence kit from Germany or Poland
| HTS: 7413.00.9000, 9903.01.33, 3%, “stranded wire, cables, plaited bands and the like, including slings and similar articles, of copper, not electrically insulated: fitted with fittings or made up into articles.” |
| Item: The product to be imported is a portable, pre-assembled electric fence kit that is designed to function as a temporary or semi-permanent fencing solution for both agricultural and residential applications. Each kit includes plastic netting, PVC posts, copper filaments, stainless steel filaments and a steel spike. The netting is constructed from horizontal and vertical strands of PE, twisted from 15 PE monofilaments, and joined at the intersections with injection-molded PE beads. One of the horizontal strands will contain three tinned copper filaments for electrical conductivity. The netting will contain up to ten additional horizontal strands that contain three stainless steel filaments each. Each PVC post is preinstalled with the netting and is reinforced with six fiberglass strands and fitted with a steel spike for anchoring in the ground. |
| Reason: The copper filaments are the component of the netting that conducts the electricity in the fence and as such, imparts the essential character of the kit in accordance with GRI 3(b). |
| Ruling Date: July 8, 2025 |