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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N350383: The country of origin and marking of battery chargers
| Origin: Indonesia |
| Item: There are five versions of what is described as a battery charger at issue with this request. The subject chargers are used in a variety of industrial and recreational machinery, such as electric pallet jacks, scissor lifts, golf carts, and e-mobility scooters. The charger consists of a printed circuit board assembly (PCBA) within a cast enclosure and incorporates various electrical connectors. The primary difference between the models is the size of the PCBA, which is dependent upon the voltage rating needed by the end customer. The manufacturing process for all five models is substantially similar and only differs slightly. This begins in Indonesia with the creation of the PCBA by adding the various electrical components, including integrated circuits, resistors, transistors, capacitors and others, through a soldering, through-hole, and surface mount technology (SMT) process to the bare printed circuit board. This finished PCBA is then tested for functionality and sent to China where it is glued within the cast enclosure. The connectors are then added before the lid is attached and the finished device is tested and packaged for shipment to the United States. |
| Reason: The PCBA, which functions to convert the input voltage and control the electrical charging of the intended machinery, imparts the character of the finished device. Further, the process performed in China is not significantly complex in nature to substantially transform the PCBA into a new and different article of commerce. |
| Ruling Date: July 9, 2025 |
N350389: The country of origin of a fixed blade knife
| Origin: Puerto Rico, Cambodia, Vietnam, or Malaysia |
| Item: A fixed blade knife with a serrated cutting edge. The knives will be made from high-carbon, stainless steel and feature triple rivet accents on the handles. The raw steel panels will be cut to the form, shape, and size of the knife blade and would be produced in either Puerto Rico, Cambodia, Vietnam, or Malaysia. Further, when knife blanks produced in either Puerto Rico, Cambodia, Vietnam, or Malaysia are sent to China for further processing, they are in the final form, size, and shape of the finished knife blades and would leave in the same state regardless of the source country. In China, these knife blanks will be heat treated. The handles, made from either injection molded plastic or stamped metal that is welded over the end, will then be added to the knives. The handles of the blade are then ground to their final shape. Next, the knife edges are cut, and finally, the finished knives are cleaned, polished, inspected, and packaged for export to the United States. |
| Reason: The knife blanks hold the essential identity of the finished knives and that they are not substantially transformed to become new articles having a new name, character, or use after being further processed in China. As such, the country of origin for this serrated knife would be the source country of either Puerto Rico, Cambodia, Vietnam or Malaysia. |
| Ruling Date: July 9, 2025 |
N350393: The tariff classification of blood glucose monitoring system from China
| HTS: 9027.89.4530, 9903.01.24; 9903.01.25; 9903.88.01; 9817.00.96, free, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus: Other: Other: Electrical: Chemical analysis instruments and apparatus.” |
| Item: The iHealth Wireless Smart Gluco-Monitoring System (iHealth Gluco+), which is a device that allows users to measure and track their blood glucose levels using a smartphone or tablet. It connects via Bluetooth and automatically records readings in the iGluco app, eliminating the need for manual logging. The system includes the iHealth Wireless Smart Glucose Meter, iHealth Glucose Test Strips (EGS-2003), and the iHealth Gluco-Smart App (mobile application). This system is designed for use by individuals with diabetes to self-monitor blood glucose levels. The accompanying mobile application provides real-time tracking and data analysis for ongoing diabetes management. The system can measure blood samples drawn from various body sites, including the fingertip, palm, forearm, upper arm, calf, or thigh, making it adaptable and convenient for users with mobility or dexterity challenges. |
| Reason: The essential character of the iHealth Wireless Smart Gluco-Monitoring System (iHealth Gluco+) is imparted by the glucose meter. The iHealth Wireless Smart Gluco-Monitoring System performs a chemical analysis on a diabetic’s blood sample to determine if their levels are too high or too low, which is a direct link to the physical impairment. Accordingly, the iHealth Wireless Smart Gluco-Monitoring System is specifically designed for use by the handicapped for secondary classification purposes. |
| Ruling Date: July 9, 2025 |
N350412: The tariff classification of a patient lift from Canada
| HTS: 8428.90.0390, 9903.01.10; 9903.01.26; 9817.00.96, free, “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery: Other.” |
| Item: The Amico Go-Lift Patient Lift System, which is described as a ceiling-mounted patient lift designed to lift patients who have limited mobility or who cannot move independently due to age, injury, surgery, illness, or disability. Its main components include dual electric motors, a battery pack, a printed circuit board assembly, a wired control pendant, and a strap assembly with a carry bar that functions as an attachment support for a patient sling. The battery-powered DC motors provide a maximum lifting capacity of 700 pounds at a maximum lifting speed of one inch per second. The patient lift will be imported as a fully assembled unit and is only sold through authorized and certified medical equipment distributors or specialty stores. It will not be available for purchase by the general public. |
| Reason: The Amico Go-Lift Patient Lift System, model number GO-LIFT-700 satisfies the five factors set out by CBP. As a result, it is the opinion of this office that a secondary classification will apply in subheading 9817.00.96, HTSUS. |
| Ruling Date: July 9, 2025 |
N350419: The tariff classification of a magnetizer from South Korea
| HTS: 8505.11.0070, 9903.01.25, 2.1% + 10%, “Electromagnets; permanent magnets and articles intended to become permanent magnets after magnetization; electromagnetic or permanent magnet chucks, clamps and similar holding devices; electromagnetic couplings, clutches and brakes; electromagnetic lifting heads; parts thereof: Permanent magnets and articles intended to become permanent magnets after magnetization: Of metal: Sintered neodymium-iron-boron.” |
| Item: The merchandise under consideration is identified as the E-Zen multi-function magnetizer, and is described as an accessory for 1/4-inch hex bits. It consists of a cylindrical polyethylene body with a knurled grip and a slight taper at one end. Inside the body is a hollow steel core equipped with a neodymium ring magnet at each end. The magnetizer is used to temporarily add, strengthen, or remove magnetic fields from driver bits or screwdrivers. Its overall dimensions are approximately 18.8 millimeters in diameter and 20.5 millimeters in length. |
| Reason: The essential character of the subject magnetizer is imparted by the neodymium ring magnets. |
| Ruling Date: July 9, 2025 |
N350562: The country of origin and marking of photovoltaic junction boxes
| Origin: Malaysia or Thailand |
| Item: There are two items at issue with this request, which are each described as photovoltaic junction box assemblies, or jboxes. The first jbox is comprised of a plastic housing within which are electrical terminals and an optional semiconductor diode. Attached to the terminals are two insulated electrical conductors, one with a positive polarity and one with a negative polarity, that extend from the housing. At the end of each conductor are specific electrical connectors designed to be attached to a solar panel after importation. The second jbox is comprised of three plastic housings that contain electrical terminals and optional semiconductor diodes. Two insulated electrical wire harnesses extend from the housings, one with a positive polarity and one with a negative polarity. At each end of the harness are electrical connectors designed to be attached to a solar panel after importation. In use, both jbox assemblies function identically. The subject devices are specifically used as a subcomponent in solar panel assemblies in order to supply the generated electricity from the panel to the outside source. The assembly process for the subject jboxes is substantially similar. Insulated, complete wire harnesses are manufactured in Thailand or Malaysia and shipped on reels to China. In China, the cables are cut to length and the ends are stripped prior to the connectors being attached. The diodes are then placed into the plastic housings before the harnesses are welded onto the terminals within the housing. The housing is then closed and the completed device is tested and packaged for shipment to the United States. |
| Reason: The insulated harnesses impart the character of the finished devices as they provide the principal electrical component. Further, the processes performed in China do not substantially transform the harnesses into new and different articles of commerce. The country of origin for marking and trade remedy purposes of the jbox assemblies will be Malaysia or Thailand, where the harness originates. |
| Ruling Date: July 9, 2025 |
N350568: The tariff classification of steel structures from Mexico
| HTS: 7308.90.9590, 9903.81.90; 9903.01.33, 9903.01.01, free + 50% + 25%, “Structures (excluding prefabricated buildings of heading 9406) and parts of structures (for example, bridges and bridge sections, lock gates, towers, lattice masts, roofs, roofing frameworks, doors and windows and their frames and thresholds for doors, shutters, balustrades, pillars and columns) of iron or steel; plates, rods, angles, shapes, sections, tubes and the like, prepared for use in structures, of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The products under consideration are unassembled ladders and platforms. After assembly, the ladders and platforms attach to the exterior of the exhaust stack of a gas turbine and allow access to the testing ports. All components are shipped together and ready for installation after importation into the United States. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350582: The tariff classification of sample hats and golf bags from Vietnam
| HTS: 9811.00.60, free, “any sample (except samples covered by heading 9811.00.20 or 9811.00.40), valued not over $1 each, or marked, torn, perforated or otherwise treated so that it is unsuitable for sale or for use otherwise than as a sample, to be used in the United States only for soliciting orders for products of foreign countries.” |
| Item: Four styles of golf themed hats which have printed text that reads “SAMPLE NOT FOR SALE” on the inside of the hats. Item 5, identified as a “Titleist Golf Bag,” is a golf bag with a compartmentalized top for sorting the clubs, two kickstand legs, and several outer pockets for related accessories. The sample is pale pink in color. On one side of the bag, in 1 inch high black lettering, is the word “SAMPLE.” On the other side of the bag, in a 12 inch by 1.5 inch text box, also in black, are the words “SALES SAMPLE NOT FOR RESALE” with the words “Not designed for use/sales sample only” framed in black on a second line within the same text box. The samples are permanently marked with the phrase “sample not for sale” in indelible ink. Additionally, each sample is labeled with a SKU number that includes the identifier “SS” to signify its status as sample; which is also documented on all import documentation such as invoices and packing lists. The distribution plan for the hat and the bag samples will entail direct shipping to approximately 90 sales representatives across the country. Each shipment will consist of pre-packed sets that feature various hat types and colorways with each set containing between 4 and 17 hats. Furthermore, all samples will be permanently marked and clearly designated as samples; and while the items are not mutilated, the indelible marking ensures their unsuitability for commercial sale. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350636: The tariff classification of women’s knit blouses from China
| HTS: 6106.10.0010, 9903.01.24; 9903.01.25; 9903.88.15, 19.7% + 20% + 10% + 7.5%, “Women’s or girls’ blouses and shirts, knitted or crocheted: Of cotton: Women’s.” |
| Item: Style 1 is a women’s blouse constructed from 100% cotton terry knit fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from the shoulders to below the waist and features a self-fabric lined hood with a drawstring, long sleeves with rib knit cuffs, contrasting color embroidery at the outer hood, front panel and outer sleeves, a slightly longer back panel, and a rib knit bottom with notched side seams. Style 2 is a women’s blouse constructed from 100% cotton terry knit fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from the shoulders to below the waist and features a rib knit crew neckline, long sleeves with rib knit cuffs, contrasting color embroidery at the front panel, and a rib knit bottom with notched side seam. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350727: The country of origin of a washing machine speed sensor
| Origin: China |
| Item: A washing machine motor speed sensor. The subject device comprises a printed circuit board assembly (PCBA), upon which is a Hall Effect sensor, that is enclosed within a plastic housing. Extending from the housing is a wire harness with a specialized electrical connector at the end. In use, the subject sensor is attached to the motor of a washing machine, which incorporates a magnet. The Hall Effect sensor within the subject device creates an electromagnetic field that, when broken by the magnet within the motor, sends an electrical signal to the control unit of the washing machine, which alerts the device to the appropriate speed of the motor. The PCBA with the necessary Hall Effect sensor is manufactured in China. This PCBA is then sent to Thailand where the wire harness, also of Chinese origin, is attached and then enclosed within the plastic housing. A Chinese connector is then attached to the end of the harness before the finished device is tested and packaged for shipment to the United States. |
| Reason: The Chinese PCBA with incorporated Hall Effect sensor imparts the character of the finished device. Further, the assembly process performed in Thailand is simple in nature and does not substantially transform the PCBA or other Chinese components into new and different articles of commerce. |
| Ruling Date: July 9, 2025 |