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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N350800: The country of origin of Bluetooth earbuds
| Origin: Philippines |
| Item: The items concerned are Bluetooth wireless earbuds and their charging case, which are made from components sourced from the Philippines and China. The actual manufacturing/assembly steps are undertaken in the Philippines. The manufacturing steps that take place in the Philippines include in part: All plastic housing components are produced. All printed circuit boards are manufactured. All printed circuit boards are populated using surface mount technology. The components of the PCBAs are sourced mainly from the Philippines with only the integrated circuits, batteries, silicon microphone, and USB-C connector being of Chinese origin. PCBA testing Solder speaker to earbud PCBA Solder battery to the earbud PCBA. Assemble PCBA with the middle earbud housing. Assemble top and middle earbud housing together. Test charging capability Assemble bottom housing to middle housing. Clean, inspect and various testing. Magnets for charging case assembled/installed. Battery is soldered to charging case PCBA assembled/installed in inner bottom cover of charger case |
| Reason: The manufacturing processes that take place in the Philippines are both meaningful and complex, resulting in the creation of wireless Bluetooth earbuds and their charging case. The various components used in the manufacturing process are substantially transformed into a different article with a new name, character and use as a result of the processing that takes place within the Philippines. Therefore the country of origin of the finished wireless Bluetooth earbuds and their charging case will be the Philippines. |
| Ruling Date: July 10, 2025 |
N350803: The tariff classification, country of origin and marking of tap and die sets
| HTS: 8207.40.6000, 9903.01.25, 4.8% + 10%, “interchangeable tools for handtools, whether or not power operated, or for machine tools …: tools for tapping or threading, and parts thereof: other.” |
| Origin: Thailand |
| Item: The items under consideration are four separate tap and die sets. A tap and die set is a tool set used to create or repair screw threads on both internal and external surfaces. Taps are used to cut internal threads within a hole in a workpiece, while dies are used to cut external threads on screws, bolts, rods, or studs. Tap wrenches and die stocks hold the tap or die while in use. The taps and dies are made of heat treated and tempered high carbon steel, and the cutting parts contain by weight less than 0.2% molybdenum. Sets one and two will be imported packaged in a blister card, while sets three and four will be imported in fitted blow molded cases. For each set, the tap wrenches and die stock are of Chinese origin, while the taps and dies originate from Thailand. |
| Reason: The essential character of these tap and die sets is imparted by the taps and dies. 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 taps and dies are products of Thailand and are classified within the tariff provision that the complete sets are classified. Accordingly, the country of origin of the four tap and dies sets for Section 301 and other duty purposes is Thailand. |
| Ruling Date: July 10, 2025 |
N350824: The tariff classification of an aircraft from Germany
| HTS: 8802.30.0180, 9903.01.25, free + 10%, “Other aircraft (for example, helicopters, airplanes, except unmanned aircraft of heading 8806); spacecraft (including satellites) and suborbital and spacecraft launch vehicles: Airplanes and other aircraft, of an unladen weight exceeding 2,000 kg but not exceeding 15,000 kg: Used or rebuilt: Other aircraft.” |
| Item: The article under consideration is a used 2022 Aircraft, Tecnam P2012 Special Missions Platform (SMP), which is designed for carrying aerial mapping sensors. It is equipped with two Next Generation electronically controlled turbo-charged piston engines. The aircraft contains two large 24” factory engineered and installed camera ports and 140 amps high output sensor power. The aircraft is designed to sit eleven (11) passengers. It features Garmin products, such as avionics suite, autopilot, flight stream, flight management system, etc., and Bose A30 Headsets for the operators. The unladen weight of the aircraft is 2,416 kg. |
| Reason: N/A |
| Ruling Date: July 10, 2025 |
N350838: The country of origin of optical windows
| Origin: Thailand |
| Item: The merchandise under consideration is described as an optical window for use with various riflescopes. The subject article is a plate of optical glass that is designed to add various optical properties, including allowing only certain wavelengths of light into the scope, as well as to seal the end of the riflescope in order to protect against contamination and moisture. At importation, the subject window is not permanently mounted within any enclosure. Unworked glass in the form of pucks, sheets, bars, or rods is manufactured in either Japan or China and shipped to Thailand. In Thailand, the glass is then cut to the desired shape before they undergo various stages of grinding and milling. This process creates and refines the desired optical properties of the window. The window is then shipped to China where it is coated prior to being packaged for shipment to the United States. |
| Reason: The process performed in Thailand produces the desired optical properties and is the critical stage of manufacturing of the end product. This process substantially transforms the glass raw material into a new and different article of commerce. Further, the coating process performed in China is simple in nature and would not significantly alter the properties of the window. Based upon the facts presented, the country of origin of the riflescope optical window will be Thailand. |
| Ruling Date: July 10, 2025 |
N350848: The country of origin of an LVDS cable
| Origin: Thailand |
| Item: There are two items at issue with this request, which are described as Low Voltage Differential Signaling (LVDS) cables. The subject cables consist of two copper core conductors and a single drain wire twisted together and wrapped in braiding, jacketing, and insulation. The cables are imported on reels and not terminated with connectors on either end. The subject cables are identical and are used as high-speed data cables within vehicle infotainment systems to transfer audio, video, and other data signals. The manufacturing process begins in Thailand with the creation of the copper conducting cores. Each core is manufactured by winding multiple individual copper wires, of Thai origin, together. These cores are then sent to China where they are wrapped with insulating adhesive and then two cores are twisted together with a single drain wire. These two cores are then wrapped with a mylar layer and plastic tape. This semi-finished cable is then shipped to India where it is wrapped with aluminum and tinned-copper braiding to create a shield. The cable is then jacketed with insulation before the finished cable is tested and prepared for shipment to the United States. |
| Reason: The two copper cores, which are stranded and wound in Thailand, impart the character of the finished cable as they are the primary electrical conducting component. The various steps performed in both China and India do not substantially transform the cores into new and different articles of commerce. Accordingly, the country of origin of the LVDS cables will be Thailand. |
| Ruling Date: July 10, 2025 |
N350851: The country of origin of USB cables
| Origin: Thailand |
| Item: There are two items at issue with this request, which are described as USB cables. The subject cables are constructed of four copper core conductors and a single drain wire, which are twisted together and wrapped in braiding, jacketing, and insulation. The cables are imported on reels and not terminated with connectors on either end. The manufacturing process begins in Thailand with the creation of the copper conducting cores. Each core is manufactured by winding multiple individual copper wires, of Thai origin, together. The cores are then sent to China, where each core is wrapped with an insulating adhesive. Two of these cores are then mechanically twisted together to form a twisted pair and shipped to India, along with two other insulated cores, which are not twisted together. In India, the twisted pair and two untwisted insulated cores are wrapped with mylar tape and tinned-copper braiding to create a shield. The cable is then jacketed with insulation before the finished cable is tested and prepared for shipment to the United States. |
| Reason: The four copper cores, which are stranded and wound in Thailand, impart the character of the finished cable as they are the primary electrical conducting component. The various steps performed in both China and India do not substantially transform the cores into new and different articles of commerce. Based upon the facts presented, the country of origin of the USB cables will be Thailand. |
| Ruling Date: July 10, 2025 |
N350866: The classification and country of origin determination for a textile basket; 19 CFR 102.21(c)(2)
| HTS: 6307.90.9891, 9903.01.24; 9903.01.25; 9903.88.15, 7% + 20% + 10% + 7.5%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Origin: China |
| Item: The item, described as a “Fabric Bunny Basket,” is a decorative basket designed and intended for use in the home. The open top, round-shaped basket is composed of 100% polyester woven fabric over ethylene vinyl acetate (EVA) plastic. The liner is composed of 100% nylon woven striped dyed pink or blue fabric. The rim of the basket is folded over a 2 ½ millimeter diameter iron wire and sewn closed. The item measures 8 ½ inches in diameter and 14 ½ inches in height and features a handle and two floppy bunny ears composed of the same fabric sewn to the top edge. The bunny ears measure 7 ½ inches in length by 3 inches in width and hang down on the front of the basket. The basket also features a white pompom glued to the bottom front of the basket to depict a tail. The pertinent manufacturing operations for the bunny basket are as follows: In China: Outer layer: 100% polyester fabric is woven, dyed, and shipped in rolls to Cambodia. Liner: 100% nylon fabric is woven, dyed, and shipped in rolls to Cambodia. Iron wire, EVA, pompom, and sewing thread are produced and shipped to Cambodia. In Cambodia: The fabric, EVA, and iron wire are cut. The outer layer fabric is laminated to the EVA. The outer layer, liner, handle, and bunny ears are sewn. The pompom is glued to the basket. |
| Reason: The textile basket is composed of two textile fabrics sewn together, and each of these fabrics are formed by a fabric-making process in a single country, that is China. Therefore, pursuant to 19 CFR 102.21(c)(2), the country of origin of the textile basket is China. |
| Ruling Date: July 10, 2025 |
N350965: The country of origin of a bow rake
| Origin: Vietnam |
| Item: The item under consideration is a bow rake which features a rake head with sixteen curved steel tines. Two steel bows extend from the sides of the rake head and attach it to a handle at a right angle. The rake is commonly used for spreading mulch, weed removal, tamping soil, breaking up compacted soil, and removing roots and rocks from cultivated beds. The manufacturing process begins in Vietnam, where Chinese-origin hot-rolled steel is laser-cut into a flat outline of the rake head. The tines of the rake head are then bent into their curved shape. Also in Vietnam, round steel is punched and pressed into two bows, which are then welded to the sides of the rake head at a right angle. These welded pieces are sent to China, where they are polished and powder coated. A handle socket is connected and secured to the bows, along with a wooden and fiberglass handle. Finally, middle and end plastic grips are attached to the handle. |
| Reason: The raw steel is substantially transformed in Vietnam into a fully formed rake head. It is the rake head that contributes to the main functionality of the tool. Based upon the finishing operations performed in China, the rake head is not substantially changed so as to transform it into a new article with a different name, character, or use. Therefore, the country of origin of the finished bow rake is Vietnam. |
| Ruling Date: July 10, 2025 |
N349953: Classification and country of origin determination for an outdoor pillow; 19 CFR 102.21(c)(2); tariff shift
| HTS: 9404.90.2090, 6%, “Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Other: Pillows, cushions and similar furnishings: Other: Other.” |
| Origin: U.S. |
| Item: The outdoor pillow consists of an outer shell of 100% acrylic fabric woven in a striped pattern and stuffed with 100% polyester fiberfill. The pillow has knife edges and measures 16 X 16 inches. The manufacturing operations for the outdoor pillow are as follows: In the United States: Acrylic fabric is woven. Acrylic woven fabric is exported to China. In China: Polyester fiberfill is formed. Acrylic fabric is cut and assembled into a pillow shell by sewing. Pillow shell is stuffed with polyester fiberfill and sewn closed. Pillow is packed and exported to the United States. |
| Reason: As the only fabric incorporated in the pillow, the fabric forming the shell of the pillow, is formed in a single country, that is, the United States, as per the terms of the tariff shift requirement, country of origin is conferred in the United States. |
| Ruling Date: July 9, 2025 |
N349998: Classification and country of origin determination for two quilts and one sham; 19 CFR 102.21(c)(2); tariff shift; 19 CFR 102.13; De Minimis
| HTS: (quilts) 9404.40.9005, 12.8%, “Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Quilts, bedspreads, eiderdowns and duvets (comforters): Other: With outer shell of cotton.” (quilted sham) 9404.90.9605, 7.3%, “Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Other: Other: Other: With outer shell of cotton.” |
| Origin: Pakistan |
| Item: Quilts made of 100% cotton woven fabric. The face of the quilts includes printing, embroidery and appliques to create a jungle scene. The appliques include a nonwoven backing. The quilt is filled with 100% polyester fiberfill. The fiberfill is prevented from shifting by an internal nonwoven scrim. The edges are finished with a binding fabric in a contrasting color. The matching quilted sham features the same construction and details as the quilt. The quilt and sham will be sold separately. The manufacturing operations are as follows: In Pakistan, greige cotton face and back fabric is formed. Fabric is exported to China. In China, Nonwoven scrim and nonwoven backing for appliques is formed. The face and back fabrics are bleached, dyed and shrunk. Face fabric is printed, embroidered and appliqued. Applique fabrics are dyed. The fabrics are cut and sewn. Shells are filled with polyester fiber fill closed and hand quilted. The quilts and sham are packaged and exported to the United States. |
| Reason: The quilt and pillow sham are made from fabrics made from two countries; the face and back fabric is woven in Pakistan and the nonwoven fabric is formed in China. In this case, however, the nonwoven fabric is disregarded in accordance with Section 102.13, the De Minimis rule. As the nonwoven fabric does not constitute more than 7% of the total weight of the quilt and shams, the nonwoven fabric is disregarded in determining the country of origin for these items. As the remaining fabric forming the quilt and sham is formed by the fabric making process in a single country, that is, Pakistan, as per the terms of the tariff shift requirement, country of origin is conferred in Pakistan. |
| Ruling Date: July 9, 2025 |