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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N350000: The tariff classification of White Rum from Dominican Republic
| HTS: 2207.10.3000, 9903.01.25, 18.9 cents/pf. liter + 10%, “Undenatured ethyl alcohol of an alcoholic strength by volume of 80 percent vol. or higher; ethyl alcohol and other spirits, denatured, of any strength: Undenatured ethyl alcohol of an alcoholic strength by volume of 80 percent vol. or higher: For beverage purposes.” |
| Item: The subject merchandise is described as White Rum. The product will be made by distilling rum wash obtained via the alcoholic fermentation of sugar cane juice to 189 proof, which equals 94.5% alcohol by volume (ABV). No pure alcohol, spirits, flavorings, colorings, or other ingredients are said to be added to the distillate, nor will it be sweetened. The product will be imported in International Organization for Standardization (ISO) containers of 6.4 Water Gallons (WG). |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350030: The country of origin and marking of Body Spray Mists
| Origin: Singapore or Thailand |
| Item: The Body Spray Mists will consist of a single fragrance supplied from either Singapore or Thailand. The perfume base will be shipped to China where it will be blended with alcohol, propylene glycol and water. The blending process does not involve any chemical reactions and that it simply decreases the viscosity of the fragrance so that it may be applied via a spray mechanism. After the blending process, the solution may be left standing for a certain specified period, in other cases it is cooled to a prescribed temperature and filtered before packaging. The final blend is packaged in China into either pump spray bottles or aerosol spray cans in which case propellants are also added. All packaging materials (bottles, caps, cans, and cartons) originate in China. |
| Reason: The changes in concentration and viscosity which occur in China, do not result in a substantial transformation for origin purposes. The country of origin of the body spray mists will be Singapore or Thailand. |
| Ruling Date: July 9, 2025 |
N350142: The country of origin of potato products from China
| Origin: China |
| Item: The subject merchandise, “Wasabi Salt French Fries,” and “Garlic Butter Potato Snacks,” are potato-based snacks. Both products are said to be sold in single serving sizes. The manufacturing of the products commences with potatoes that are grown in China. Once harvested, the manufacturing process continues in a Chinese factory where the potatoes are cut into French fry shapes or thick potato slices and then fried in vegetable oil. The products are then shipped to a factory in Japan where they are seasoned and packaged. Product one, “Wasabi Salt French Fries,” includes an ingredients breakdown. The ingredients sourced from China include potatoes (89%) and vegetable oil (7%). Product two, “Garlic Butter Potato Snacks,” includes an ingredients breakdown. The ingredients sourced from China include potatoes (61%) and vegetable oil (33%). The balance of the ingredients in both products consists of seasoning sourced from Japan, Malaysia, Thailand, United States, Canada, Germany, Netherlands, Vietnam, India, France, Brazil, Morocco, and the Philippines. |
| Reason: The manufacturing process performed in Japan, which consists of seasoning the fries and chips, would not effect a substantial transformation. Accordingly, the products will be considered a product of the country in which the potatoes are grown and harvested, which in this case is China. |
| Ruling Date: July 9, 2025 |
N350161: The tariff classification of seating components from Thailand
| HTS: (items 1 thru 5, if made of reinforced or laminated plastics) 9401.80.2011, 9903.01.25, free + 10%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats: Of rubber or plastics: Of reinforced or laminated plastics: Other household.” (items 1 thru 5, if not made of reinforced or laminated plastics) 9401.80.4046, 9903.01.25, free + 10%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats: Of rubber or plastic: Other: Other: Other. (item 6) 9401.99.3580, 9903.01.25, free + 10%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of rubber or plastics: Other.” (item 7) 9401.61.4011, 9903.01.25, free + 10%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with wooden frames: Upholstered: Chairs: Other: Other household.” |
| Item: Item 1, the “Full Sofabed - Dark Gray, item 2, the “Queen Sofabed-Dark Gray,” item 3, the “Single Sofabed-Dark Gray,” item 4, the “Chaise Sofabed-Dark Gray,” and item 5, the “Corner Sofabed-Dark Gray,” are modular upholstered seats constructed of pocket coil springs and foam encased in textile with Velcro straps. Each seat is not constructed of metal, wood, or plastic straight, concave, or convex frame rails, but primarily foam cushions. Items 1 through 5 are separate and independent components that can be configured and reconfigured. When configured and reconfigured, each seating component may alternatively function as a bed, however, each seating component does not have a separate and removeable mattress component. Each of the seating components will be made available for retail as both individual units and as modular combinations (2-piece, 3-piece, or 4-piece sectionals) depending on customer preference and will include accent pillows. Item 6, the “Armrest/Backrest,” is an upholstered seat component constructed of particleboard and foam encased in textile with Velcro strips. The seating components are not permanently affixed to the structural frame of a seat. Velcro straps are located at the base of the armrests/backrests; the Velcro straps allow the seating components to be positioned, repositioned, and removed according to user preference. The armrest/backrest components will be imported and sold separately. Item 7, the “Ottoman-Dark Gray,” is an upholstered seat affixed to a plywood and wood frame. Seating is provided for a single individual, and a storage compartment is located at the base of the seat foundation. The ottoman cushion is constructed of foam encased in textile. Textile webbing and an “S” spring located beneath the seat foundation provides comfort, support, and is permanently affixed to the wooden frame. The ottoman contains no exposed solid wood. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350173: The tariff classification of an LED clip-on light from China
| HTS: 8513.10.4000, 9903.01.24; 9903.01.25; 9903.88.03, 3.5% + 20% + 10% + 25%, “Portable electric lamps designed to function by their own source of energy (for example, dry batteries, storage batteries, magnetos), other than lighting equipment of heading 8512; parts thereof: Lamps: Other.” |
| Item: A clip-on light that consists of a cylindrical plastic housing with an LED lamp covered by clear lens at one end and a push button switch at the other end. The housing has two wing-like pieces forming a clip to clip the light onto a cylindrical object. The light is powered by one AA battery contained in the housing. In your ruling request submission, you state that the clip-on light is specially designed to attach to the StrongArm Comfort Cane (one of your company’s products). These clip-on lights can be attached to other mobility devices such as walkers and wheelchairs, if their tubing diameters are compatible. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350184: The tariff classification of a food preparation from Taiwan
| HTS: 2106.90.9998, 9903.01.25, 6.4% + 10%, “food preparations not elsewhere specified or included…other… other…other.” |
| Item: The products, “Brand’s Essence of Chicken,” and “Brand’s Essence of Chicken with Cordyceps Extract,” are essence drinks intended for human consumption to be potable directly from the bottles. Both products contain approximately 99% concentrated chicken extract and caramel (coloring). Brand’s Essence of Chicken with Cordyceps Extract also contains dong quai (angelica sinensis) root extract, Chinese licorice (Glycyrrhiza uralensis) root extract, and cordyceps (Cordyceps sinensis) extract. The products will be imported for retail sale in 2.3-ounce bottles. The products are manufactured from chicken that is purchased from the USA. In Taiwan, the raw chicken is minced and loaded into a pressure cooker. At the conclusion of the heating cycle, the interim product is sieved, which removes all the meat and bones. The liquid fraction is further filtered mechanically to produce a clear liquid essence of chicken drink by removing the fat fraction. The clear liquid is then concentrated through an evaporator to remove excess water. Diatomaceous earth is added to remove all meat fibers and bone residues with diatomaceous earth produce a clear liquid. Caramel is added to the clear liquid Essence of Chicken Drink and mixed with additional water added. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350185: The country of origin of faucets
| HTS: 8481.80.9050, 9903.01.24; 9903.01.25; 9903.88.03, 2% + 20% + 10% + 25%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Other: Other: Other.” |
| Origin: China |
| Item: The Dual Sensor Touchless Pull-Down Kitchen Faucet in Brushed Nickel with 4-function Turbo Spray and Fast Mount. The faucets, which are unassembled sets, consist of a faucet body with a cartridge valve and a solenoid valve, a battery box, and a sprayer head packaged together ready for retail sale. With respect to origin, the assembly of the faucet sets occurs in Thailand and consists of valves, and other components from China. To assemble the faucet spout, an oiled O-ring seal is installed into the corresponding connection of the cartridge valve, which is subsequently installed into the body of a faucet. Then a solenoid valve core sourced from China is pressed into a seat sourced from China. Afterwards, a lubricated O-ring is installed into a seal. The seal and O-ring are then installed into a corresponding connector, which is subsequently installed into the body of the faucet. The battery box is also assembled in Thailand, which is completed by screwing a cover to a battery box from China. Afterwards, batteries are placed in a bag and then taped to the box. Also, assembled in Thailand are a base plate, a pipe sleeve bushing, and an outlet pipe with a pull-out hose. The faucet and the battery box are then packaged with the spray head. |
| Reason: The cartridge and solenoid valves are of Chinese origin. Therefore, as the country of origin of the valves is China, the country of origin of the three faucet sets is China. |
| Ruling Date: July 9, 2025 |
N350337: The tariff classification of Ammonium Perchlorate Solution from Germany
| HTS: 2829.90.6100, 9903.01.25, 3.7% + 10%, “Chlorates and perchlorates; bromates and perbromates; iodates and periodates: Other: Other: Other.” |
| Item: The product at issue is described as a solution of a chemical compound, ammonium perchlorate (CAS # 7790-98-09) and water (CAS # 7732-18-5). The Ammonium Perchlorate Solution is a colorless, odorless, liquid, with the empirical formula NH4ClO4. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |
N350346: The tariff classification, country of origin and marking of a floor installation kit
| HTS: 8205.59.5560, 9903.01.25, 5.3% + 10%, “Handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: other: other: of iron or steel: other: other (including parts).” |
| Origin: Vietnam |
| Item: The merchandise under consideration is a floor installation kit. The kit includes a rubber mallet, steel pull bar, plastic tapping block and a 100-pack of laminate spacers. The items are used in conjunction with each other to install laminate and wood flooring. The rubber mallet, tapping block and 100-pack of laminate spacers are of Chinese origin, and the pull bar is of Vietnamese origin. The items will be packaged for retail sale in China before importation into the United States. |
| Reason: If the HTSUS provision under which the entire set is classified is not covered by the Section 301 remedies, but the set contains components that are classified in a subheading covered by the 301 list, the 301 duties will not be assessed on the individual components. Following this guidance, the pull bar is a product of Vietnam and is classified within the tariff provision that the complete set is classified. Accordingly, the country of origin of the floor installation kit for Section 301 and other duty purposes is Vietnam. |
| Ruling Date: July 9, 2025 |
N350374: The tariff classification of a laminated fabric from China
| HTS: 5903.20.2500, 9903.01.24; 9903.01.25; 9903.88.03, 7.5% + 20% + 10% + 25%, “Textile fabrics impregnated, coated, covered or laminated with plastics, other than those of heading 5902: With polyurethane: Of man-made fibers: Other: Other.” |
| Item: The subject merchandise contains three layers: a thermoplastic polyurethane (“TPU) film sandwiched between a woven face layer and a knit bottom layer. The woven face is composed of 94% polyester and 6% spandex, is of plain weave construction, and weighs 100 g/m2. The double knit bottom layer is composed of 100% polyester and weighs 145 g/m2. The total fabric weighs 290 g/m2 and will be produced in widths of 57 inches. The fabric will be used to produce jackets, vests and pants. |
| Reason: N/A |
| Ruling Date: July 9, 2025 |