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:
Sign up for a free preview to unlock the rest of this article
Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.
N350275: The tariff classification of a optogenetics system from Japan
| HTS: 8543.70.9860, 9903.01.25, 2.6% + 10%, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other.” |
| Item: A wireless optogenetics system designed to be used in neuroscience research laboratories in order to manipulate certain brain function. The system consists of a wireless receiver, remote controller, infrared emitter, LED fiber optic (cannula) insertion tool, AC adapter and dummy receiver for habituation. The LED fiber optic is surgically implanted into the brain of a small target animal, such as a laboratory mouse, and a wireless receiver is attached to the end of the fiber optic. Then the remote controller with the IR emitter is used by the researcher to send signals to the wireless receivers to trigger light pulses. |
| Reason: N/A |
| Ruling Date: July 11, 2025 |
N350314: The tariff classification of aluminum foil from India
| HTS: 7607.11.3000, 9903.85.02; 9903.01.33, 5.8% + 50%, “aluminum foil (whether or not printed, or backed with paper, paperboard, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2 mm: not backed: rolled but not further worked: of a thickness not exceeding 0.15 mm: of a thickness not exceeding 0.01 mm.” |
| Item: Light gauge aluminum foil. The foil is made from type 1235 aluminum alloy and measures 0.007 mm in thickness. The foil will be imported in coils and has not been backed. |
| Reason: N/A |
| Ruling Date: July 11, 2025 |
N350420: The tariff classification of a plastic automotive body trim piece from South Korea
| HTS: 3926.30.5000, 9903.01.25, 5.3% + 10%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [f]ittings for furniture, coachwork or the like: [o]ther.” |
| Item: A center panel component of the interior door trim, designed for installation on the driver's side front door of a vehicle. It does not provide structural support nor contribute to the safety or utility of the vehicle but is intended to enhance the interior finish of the automobile. This item is primarily composed of polyurethane leather, and it would be considered an article of plastic for classification purposes. |
| Reason: N/A |
| Ruling Date: July 11, 2025 |
N350425: The tariff classification, country of origin, and marking of tool sets
| HTS: 8466.10.0175, 9903.01.25, 3.9% + 10%, “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465…; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Other.” |
| Origin: Vietnam |
| Items: The items under consideration are described as tool sets which will be imported in molded plastic cases and ready for retail sale. The contents and component origins of each set are as follows: Tool Set 1 (70 pieces): 1 - Ratchet handle (Vietnam) 2 - Adapters (Vietnam) 1 - Magnetic bit holder (Vietnam) 20 - Precision screwdriver bits (China) 37 - Screwdriver bits (China) 9 - Sockets (China); Tool Set 2 (50 pieces): 1 - T-type ratchet handle (Vietnam) 1 - Adapter (Vietnam) 1 - Bit holder (Vietnam) 32 - Screwdriver bits (China) 15 -Sockets (China); Tool Set 3 (40 pieces): 1 - Reversible ratchet handle (Vietnam) 1 - Extension bar (Vietnam) 1 - Socket coupler (Vietnam) 28 - Screwdriver bits (China) 9 - Sockets (China); Tool Set 4 (38 pieces): 1 - Reversible ratchet handle (Vietnam) 1 - Ratchet handle (Vietnam) 1 - Extension bar (Vietnam) 1 - Bit adapter (Vietnam) 1 - Stubby adjustable wrench (China) 19 - Screwdriver bits (China) 14 - Sockets (China); Tool Set 5 (138 pieces): 2 - Ratchet handles (Vietnam) 1 - Bit driver (Vietnam) 1 - Adapter (Vietnam) 4 - Extension bars (Vietnam) 16 - Hex keys (China) 8 - Combination wrenches (China) 41 - Screwdriver bits (China) 64 - Sockets (China) 1 - Spark plug socket (China) |
| Reason: In Tool Sets 1-4, the ratchet handles, functioning as tool holders, impart the essential character of the tool sets because they are used with the adapter, bits, and sockets. Without the ratchet handles, the utility of the adapters, bits, and sockets would be significantly impeded and thus the overall functionality of the tool sets would be irreparably diminished. As a result, Tool Sets 1-4 will be classified based on the ratchet handles, the components which give the sets their essential character. In Tool Set 5, the ratchet handles, bit driver, extension bars, adapter, bits, and sockets are functionally prominent, interdependent, and in relatively high quantity. However, the set also contains 16 hex keys and 8 combination wrenches which are different tools and carry separate and distinct functionalities. Consequently, no essential character can be determined per GRI 3(b), and Tool Set 5 will be classified in the heading which occurs last in numerical order per GRI 3(c). In Tool Set 5, the ratchet handles and bit driver are classified in the heading which occurs last in numerical order among those meriting equal consideration (8466). In Tool Sets 1-5, the tool holders (e.g., ratchet handles, bit drivers, etc.) of Vietnamese origin impart the essential character per GRI 3 and thus control the classification and country of origin of each set. |
| Ruling Date: July 11, 2025 |
N350426: The tariff classification of a plastic automotive body trim piece from South Korea
| HTS: 3926.30.5000, 9903.01.25, 5.3% + 10%: “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [f]ittings for furniture, coachwork or the like: [o]ther.” |
| Item: A plastic exterior component that forms part of the garnish attached to the front left fender of a vehicle. It is designed to be a decorative cover, concealing the gap between the fender and adjacent components. It does not impact the vehicle's structural rigidity, shock absorption, vibration damping, nor safety, and is merely intended to enhance the exterior finish of the vehicle. |
| Reason: N/A |
| Ruling Date: July 11, 2025 |
N350447: The tariff classification of coated wood boards from Brazil
| HTS: 4421.99.9880, 9903.01.25, 3.3% + 10%, “Other articles of wood: Other: Other: Other: Other: Other.” |
| Item: Painted finger-jointed pine boards. The boards measure approximately 16.7 mm in thickness, 16’ or 17’ in length, with various widths between 4” and 12”. The boards with width of 8” and 12” are edge-glued. The sample is surface-coated on 3 sides. In the technical data sheet submitted for the paint, it is identified as a primer for molding. |
| Reason: N/A |
| Ruling Date: July 11, 2025 |
N350520: The country of origin and marking of Scented Liquid Hand Soap
| Origin: Malaysia or Vietnam |
| Item: A scented hand soap in liquid form. The hand soap gently cleanses skin with a fresh scent and will be sold in a plastic bottle featuring an applicator pump. The raw materials used to produce the finished hand soap will be sourced from various countries. The ingredients will be sent to either Malaysia or Vietnam. In Malaysia or Vietnam, the ingredients will be weighed, homogenized, blended under controlled conditions to produce a stable bulk, and then combined with high shear mixing operations using a mixing machine. Preservatives and other ingredients will be added in a cooled-down phase. The formulation will then be bulk tested for pH, microbial content, and stability. After testing, the bulk formulation will then be sent from Malaysia or Vietnam to China. There, the product will be filled into 14 fl. oz. retail containers, affixed with retail labels, and packaged in cartons for exportation from China to the United States. All packaging materials (bottles, pumps, cartons, and cardboard) originate in China. |
| Reason: The production process in Malaysia or Vietnam results in a substantial transformation of the raw materials, sourced from various countries, used to produce the finished hand soap. Therefore, the country of origin for the subject hand soap for duty and marking purposes is Malaysia or Vietnam, based on the country where the production process occurs. |
| Ruling Date: July 11, 2025 |
N350525: The tariff classification of brassieres and undergarments from Bangladesh and China
| HTS: (Styles 1 and 3) 6212.10.9020, 9903.01.24, 9903.01.25, 9903.88.15,16.9% + 20% + 10% + 7.5%, “Brassieres…whether or not knitted or crocheted: Brassieres: Other: Other: Of man-made fibers.” (Style 2) 6108.22.9020, 9903.01.25, 15.6% + 10%, “Women’s or girls’ slips, petticoats, briefs, panties, nightdresses, pajamas, negligees, bathrobes, dressing gowns and similar articles, knitted or crocheted: Briefs and panties: Of man-made fibers: Other: Women’s.” (Style 4) 6108.92.0005, 9903.88.15, 9903.01.25, 16% + 10% + 20% + 7.5%, “Women’s or girls’ slips, petticoats, briefs, panties, nightdresses, pajamas, negligees, bathrobes, dressing gowns and similar articles, knitted or crocheted: Other: Of man-made fibers: Underwear: Underpants.” |
| Item: Style 1 is a woman’s bra constructed of 75% nylon and 25% spandex knit fabric. The bra features an adjustable hook and eye back closure, adjustable shoulder straps which feature elastic on the backside, an underwire, an imitation pearl charm decoration in the center front and elasticized edging. The country of origin is stated to be Bangladesh. Style 2 is a woman’s high rise brief constructed of 75% nylon and 25% spandex knit fabric. The undergarment features elasticized leg openings and a crotch lining. The country of origin is stated to be Bangladesh. Style 3 is a bralette constructed of 48% cotton, 47% modal and 5% spandex knit fabric. The item features elasticized scoop front and back necklines, an approximately ½ inch covered elastic bottom band, and approximately 1 ¾ inch shoulder straps. The country of origin is stated to be China. Style 4 is a woman’s boyshort style underpant constructed of 48% cotton, 47% modal and 5% spandex knit fabric. The undergarment features a narrow waistband, short leg extensions and a crotch lining. The country of origin is stated to be China. |
| Reason: N/A |
| Ruling Date: July 11, 2025 |
N350672: The country of origin of a mass air flow sensor
| Origin: Thailand |
| Item: A mass air flow (MAF) sensor manufactured in Thailand from unfinished component parts sourced from various countries. After the unfinished component parts are imported into Thailand, they will undergo a series of highly specialized modifications during the production process to ultimately create the MAF sensor. The process starts when the raw materials, including the electronic components, metal parts, and plastics, are delivered to the facility, unloaded from the truck, and opened for inspection. Once approved, materials are manually stored in the warehouse to await production. Next, the external plastic housing components are manufactured on-site using injection molding machines. Then, the printed circuit boards (PCBs) are baked in an oven before being populated with electronic components using surface mount technology (SMT) and soldering. The electronic components include resistors, capacitors, diodes, transistors, and CPU chips. The CPU chips are programmed via a tape-out programming machine with application-specific software, enabling it to process airflow data and execute embedded algorithms, turning it into a complete printed circuit board assembly (PCBA). The completed PCBAs are then optically inspected prior to laser cutting to ensure soldering accuracy and board precision. The component parts and subassemblies are then assembled into a complete MAF sensor in Thailand. The LPTC resistor, RTDs, and NTC resistor are welded to the PCBA. Then, glue is dispensed onto the insert core while also bonding the housing pins to the PCBA using wire bonding. The pin interfaces and the PCBA are then soldered. Next, the PCBA is placed in a test fixture where flow rate data is downloaded to the CPU using a software handshake protocol. This ensures each sensor can generate calibrated, non-linear outputs with less than 3% deviation. Additional steps include aging in a high-temperature oven, mechanical fastening, glue application, mesh and housing assembly, and two-point functional testing to ensure consistent performance. Final operations include laser marking, cleaning, visual inspection, and packaging. |
| Reason: The assembly process performed in Thailand is considered complex and results in a substantial transformation of the different components. The creation of the PCBA in Thailand using SMT, including the downloading of the software, generates a working PCBA capable of performing measurements. This is a new and different article of commerce with a name, character, and use distinct from the individual components. Accordingly, the country of origin of the MAF sensors will be Thailand, which is where the PCBA creation and programming occurs. |
| Ruling Date: July 11, 2025 |
N350713: The tariff classification of a control unit from China
| HTS: 8414.80.1605, 9903.01.24; 9903.01.25; 9903.88.03, free + 20% + 10% + 25%, “Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not fitted with filters; parts thereof: Other, except parts: Air compressors: Other: Stationary: Reciprocating: Not exceeding 746 W.” |
| Item: The product at issue is referred to as a control unit, which consists of a top enclosure and a box that together encase circuit boards, a valve, a front printed circuit board assembly and a reciprocating compressor with an output of 15 watts. Once secured to the bedframe using hooks and a plastic strap, the control unit inflates and deflates the internal air cylinders of the PressureGuard APM2 mattress series. This series of mattresses is designed to prevent and treat pressure injuries, such as bed sores and decubitus ulcers. |
| Reason: N/A |
| Ruling Date: July 11, 2025 |