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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N350600: 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 garnish component installed onto the outer front door panel of an automobile, specifically around the door handle area. Its primary function is to cover gaps or exposed edges near the door handle. It does not impact driving performance, mechanical operation, or electronic function, and is intended to enhance the overall appearance and finish of the interior of the vehicle. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |
N350678: The country of origin of a pet bed
| Origin: Vietnam |
| Item: A pet bed. The bed is a square-shaped iron frame with four tube legs and plastic end caps elevated several inches above the ground. The bed features a square textile panel permanently affixed to each side of the frame. There are four manufacturing scenarios. Scenario One Materials of Thailand Origin: HDPE (High-Density Polyethylene) is shipped to China to make the woven fabric. Materials of Chinese Origin: the woven fabric, metallic, and plastic components are shipped to Vietnam. Materials of Malaysian Origin: raw iron ingots are shipped to Vietnam. In Vietnam, the ingots are used to create the iron tubes and cassettes. The fabric is cut and sewn to the size of the pet bed. The iron tubes and cassettes are cut to size for the finished good. Scenario Two Materials of Thailand Origin: HDPE is shipped to China to make the woven fabric. Materials of Chinese Origin: Woven fabric is shipped to Vietnam. Materials of Malaysian Origin: Raw iron ingots, metallic and plastic components are shipped to Vietnam. In Vietnam, the production facility uses the ingots to produce the iron tubes, cassettes, and remaining iron components. The fabric is cut and sewn into the size of the pet bed. The iron tubes and cassettes are cut to size for the finished good. Scenario Three Materials of Thailand Origin: HDPE is shipped to China. Materials of Chinese Origin: Yarn created from HDPE resin, metallic, and plastic components are shipped to Vietnam. Materials of Malaysian Origin: Raw iron ingots are shipped to Vietnam. In Vietnam, the yarn is woven into the HDPE fabric. The fabric is cut and sewn into the size of the pet bed. The iron ingots are used to make iron tubes and cassettes, and they are cut to size for the finished good. Scenario Four Materials of Thailand Origin: HDPE is shipped to China. Materials of Chinese Origin: Yarn created from HDPE resin is shipped to Vietnam. Materials of Malaysian Origin: Raw iron ingots are shipped to Vietnam. Materials of Vietnamese: Metallic and plastic components. In Vietnam, the facility manufactures the iron tubes, cassettes and additional components. The yarn is used to produce HDPE fabric that is used for the pet bed. The fabric is cut and sewn to size. The iron ingots produce the iron tubes and cassettes, and they are cut to the pet bed size. |
| Reason: The Thai, Chinese, and Malaysian components undergo processing in Vietnam that are sufficiently complex and meaningful as to result in a substantial transformation, such that these components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In addition, essential parts are manufactured in Vietnam. Thus, the country of origin for the pet bed with all four scenarios, will be Vietnam. |
| Ruling Date: July 15, 2025 |
N350680: The country of origin of a carrier plate assembly for red dot sights
| Origin: Taiwan |
| Item: A carrier plate assembly, which is a component that goes into a finished red dot sight. The component consists of a carrier plate, which is a metal piece specifically designed to fit inside a red dot sight housing and a flexible ribbon cable with LED. The LED light sits on top of the carrier plate, which will eventually project a beam of red light onto a reflective lens to create an illuminated aiming point in the form of a red dot. The carrier plate is manufactured in Vietnam and the flexible ribbon cable with LED light is produced in Taiwan. Next, the two components are shipped to China for final assembly. In China, the two components are bonded together to ensure the LED light is precisely positioned on top of the carrier plate. Then the finished carrier plate assembly will be shipped to the United States for final assembly into a complete red dot sight. |
| Reason: The character of the finished carrier plate assembly is imparted by the flexible ribbon cable with LED of Taiwanese origin, which would be considered the dominant component. The carrier plate and flexible ribbon cable with LED are merely glued together in China and does not affect a substantial transformation. The flexible ribbon cable with LED retains its own identity with a predetermined end use. Therefore, since a substantial transformation does not occur as a result of the Chinese processing, the country of origin for the finished carrier plate assembly will be Taiwan. |
| Ruling Date: July 15, 2025 |
N350850: The country of origin of a hard disk drive
| Origin: Philippines |
| Item: A hard disk drive that magnetically stores data, such as documents, pictures, and videos. The Canvio HDD is an external device that can connect to a computer via a Universal Serial Bus (USB). This external hard disk drive is intended to allow users to easily transport data files on the go and free up space on an internal hard drive on one’s personal computer. The Canvio HDD comprises four main components, which are a Voice Coil Motor (VCM), which is the drive motor of the magnetic head that reads and writes the data; a Media, which is a magnetically coated disc where the data is magnetically stored; a Head Gimbal Assembly (HGA), which reads and writes the data magnetically; and a Spindle Motor (SPM), which allows the Media to rotate. In the Philippines, the VCM is assembled from components of the Philippines, Thailand or Malaysia using two different manufacturing processes. The finished assembly is known as the Head Stack Assembly. Then, the Head Disk Assembly (HDA) is produced in the Philippines. An inner stopper and gasket are mounted onto the SPM. Screws and ramps are then placed on a pallet by an operator and the bottom yoke is screwed into the SPM. The PCBA is manufactured in the Philippines via SMT using integrated circuits, resistors, capacitors, and diodes. This PCBA plays a role in data read/write control, motor control, overvoltage protection, and supports the stable operation of the Canvio HDD. The Canvio HDD is then shipped to China for final assembly. In China, the Canvio HDD is enclosed in an external case, the product ID is changed, which is where a serial number is added for the USB connector into the firmware and the “Auto Power Off” function (which allows the device to transition into a stand-by state if there has been no read/write activity for a three-minute period of time) is turned on. Further testing is performed to confirm whether data is accurately written, as well as confirming the software and formatting is correct. Lastly, the Canvio HDD undergoes its final physical appearance check and is packaged for shipment to the United States. |
| Reason: The assembly processes which take place in the Philippines, consisting of assembling the VCM, HSA, HDA, and PCBA into a single device, represent a substantial transformation of multiple components into a new and different article of commerce. The processes completed in China, consisting of enclosing the device in an external case, changing the product ID, and adding the “Auto Power Off” function, do not substantially transform the device into a different article of commerce. As a result, the Toshiba Canvio HDD is considered to be a product of the Philippines for origin purposes at the time of importation into the United States. |
| Ruling Date: July 15, 2025 |
N350880: The tariff classification, country of origin and status under the United States-Panama Trade Promotion Agreement of vinyl flooring planks from Panama (US-PATPA)
| HTS: 3918.10.1020, 5.3%, “floor coverings or plastics, whether or not self-adhesive, in rolls or in the form of tiles: of polymers of vinyl chloride: floor coverings: vinyl tile: vinyl tile consisting of a rigid solid polymer core.” |
| Origin: Panama |
| US-PATPA Eligibility: Yes |
| Item: Rigid vinyl flooring planks utilizing a click locking system for its installation. The flooring planks are made using a core of stone polymer composite (SPC), which is a mixture of calcium carbonate and polyvinyl chloride. A polyvinyl wear layer with a UV coating layer is layered over a polyvinyl visual layer and adhered to the top side of the core. Attached to the underside is irradiated crosslinked polyethylene (IXPE) closed foam acoustic padding. Large stone plastic composite (SPC) sheets are manufactured in China, Vietnam or Malaysia. Polyvinyl chloride, calcium carbonate powder and plasticizers are mixed together and compounded. The mixture is then extruded into a continuous SPC layer. This layer will form the core. Next the core SPC sheet is laminated with the PVC color layer and PVC wear layers. The SPC sheet is cooled until rigid and is then cut into rectangles of 39.5 inches x 49 inches. The large SPC sheets are shipped to Panama for the next phase of manufacturing. The first step in the process is the “cutting” process. The large sheets go through an automated cutting machine that divides it into planks of specific width. The next step is “slotting” sometimes referred to as “profiling.” In this step the tiles go through two slotting machines to create a patented “click-lock” mechanism on all four sides. The final transformation step is the “padding.” In this step an acoustical backing padding made from irradiated crosslinked polyethylene (IXPE) closed foam, sourced from China, Vietnam or Malaysia, will be bonded through a series of hot gluing rollers to the bottom of the SPC layer. This step provides the resulting SPC click flooring with required acoustic insulation properties. The tiles are then packed in groups of four to twelve planks per box and the boxes are palletized for shipment to the United States. |
| Reason: The processing performed in Panama with respect to cutting the planks, creating the “click-lock” mechanism, and adding padding does constitute a substantial transformation of the imported components into "products of" Panama. The manufacturing process in Panama transforms the non-originating components and parts to produce the finished SPC flooring tiles. It creates a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Panama. Therefore, the "product of" requirement has been satisfied. The country of origin for the SPC flooring will be Panama. The non-originating SPC sheets are classified in subheading 3920.43, HTSUS and the non-originating IXPE padding is classified in subheading 3921.19, HTSUS. Therefore, the vinyl flooring tiles with SPC core qualify for preferential tariff treatment under the United States-Panama Trade Promotion Agreement. |
| Ruling Date: July 15, 2025 |
N350913: The tariff classification of a decorative refrigerator magnet from China
| HTS: 8505.19.2000, 9903.01.24; 9903.01.25; 9903.88.03, 4.9% + 20% + 10% + 25%, “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: Other: Composite good containing flexible magnets.” |
| Item: The merchandise under consideration is a decorative refrigerator magnet that consists of a clear glass overlay with a flexible magnet backing. The glass has a rounded top and a flat base bonded to a printed image or artwork. The magnet component is composed of ferrite agglomerated with styrene-butadiene rubber. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |
N350966: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: The merchandise under consideration is described as three models of a fiber optic patch cord assembly, which are further described as fiber optic cables that consist of a fiber optic core, which consists of 2 optical fibers. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The subject cables are used within various telecommunications industries to transfer optical data signals. The manufacturing process for all 3 parts is substantially similar and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and prepared for the addition of the connectors, which are sourced from China. The connectors are then assembled onto the ends, and the finished cable is tested and packaged for shipment to the U.S. |
| Reason: The fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce. Based upon the facts presented, the origin of the fiber optic patch cord assemblies will be the United States. |
| Ruling Date: July 15, 2025 |
N351058: The tariff classification of women’s knit garments from Indonesia
| HTS: (blouses of styles 1 and 3) 6106.20.2010, 9903.01.25, 32% + 10%, “Women’s or girls’ blouses and shirts, knitted, or crocheted: Of man-made fibers: Other: Women’s.” (shorts of style 1) 6104.69.2060, 9903.01.25, 28.2% + 10%, “Women's shorts (other than swimwear), knitted or crocheted: Of other textile materials: Of artificial fiber: Shorts.” (style 2) 6104.44.2010, 9903.01.25, 14.9% + 10%, “Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: Dresses: Of artificial fibers: Other: Women’s.” (lounge pants of style 3) 6104.69.2030, 9903.01.25, 28.2% + 10%, “Women’s or girls’, suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: trousers, bib and brace overalls, breeches and shorts: Of other textile materials: Of artificial fibers: Trousers, breeches and shorts… Other: Trousers and breeches.” |
| Item: Style 1 is a women’s pajama top and bottom. Both garments are constructed from 92 percent modal, 8 percent spandex knit fabric. The blouse of style 1 measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting blouse extends from the shoulders to below the waist and features a round front neckline with a partial opening secured by a six-button left over right closure, long sleeves and a hemmed bottom. The pull-on shorts of style 1 feature a 1½ inch wide self- fabric covered tunnel elasticized waistband, side pockets and hemmed leg openings. The shorts extend from the waist to just above the knee. Style 2 is a women’s pullover sleepwear sleeveless dress constructed from 92 percent modal and 8 percent spandex knit fabric. The outer surface of the garment measures more than nine stitches per two centimeters in the direction the stitches were formed. The dress features a round neckline, finished armholes, and a finished hemline that extends to the ankle. Style 3 is a women’s pajama top and bottom. Both garments are constructed from 63 percent lyocell, 34 percent polyester and 3 percent spandex knit fabric. The blouse of style 3 measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting blouse extends from the shoulders to below the waist and features a round neckline, hemmed, short sleeves, and a straight, hemmed bottom. The lounge pants of style 3 feature a 1½ inch wide self-fabric covered elasticized waistband, and side slits at hemmed leg openings. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |
N351124: The tariff classification of wire rope cables from Mexico
| HTS: 7312.10.7000, 9903.81.90; 9903.01.33, free + 50%, “Stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: Stranded wire, ropes and cables: Ropes, cables and cordage other than stranded wire: Other: Fitted with fittings or made up into articles.” |
| Item: Steel stranded wire rope cables which are used for multiple purposes in heavy-duty trucks. Part # 1 is a galvanized, nonalloy steel wire rope cable of 7 x 7 construction consisting of a seven-strand rope with each strand having seven wires around a single strand nonalloy steel core. The cable is approximately 200 millimeters (8 inches) in length, and 2/32 of an inch (2.38mm) in diameter. A steel ring terminal is crimped on one end of the cable and a steel cotter pin is affixed to a loop on the other end. Part # 2 is a galvanized, nonalloy steel wire rope cable of 7 X 7 construction consisting of a seven-strand rope with each strand having seven wires around a single strand nonalloy steel core. The cable is 879 millimeters (34.6 inches) in length and 4.75 mm (0.187 inches) in diameter and has fittings attached on both ends. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |
N351205: The tariff classification of women’s knit garments from Vietnam
| HTS: (blouses of styles 1 and 2) 6106.20.2010,9903.01.25, 32% + 10%, “Women’s or girls’ blouses and shirts, knitted, or crocheted: Of man-made fibers: Other: Women’s.” (lounge pants of style 1) 6104.69.2030, 9903.01.25, 28.2% + 10%, “Women’s or girls’, suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear), knitted or crocheted: trousers, bib and brace overalls, breeches and shorts: Of other textile materials: Of artificial fibers: Trousers, breeches and shorts… Other: Trousers and breeches.” (lounge pants of style 2) 6104.63.2011, 9903.01.25, 28.2% + 10%, “Women’s or girls’, suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches, and shorts (other than swimwear), knitted or crocheted: trousers, bib and brace overalls, breeches, and shorts: Of synthetic fibers: Other: Other: Trousers, breeches and shorts: Women’s: Other.” |
| Item: Style 1 is a women’s pajama top and bottom. Both garments are constructed from 50% rayon, 28% polyester and 22% nylon knit fabric. The blouse of style 1 measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting blouse extends from the shoulders to below the waist and features a boat neck, hemmed, long sleeves with flared cuffs, and a hemmed bottom. The lounge pants of style 1 feature a self-fabric covered 3½ inch-wide elasticized waistband, and flared, hemmed leg openings. Style 2 is a women’s pajama top and bottom. Both garments are constructed from 48% rayon, 48% polyester and 4% spandex knit fabric. The blouse of style 2 measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting blouse extends from the shoulders to below the waist and features a round neckline with a front placket that is lined with five non-functional buttons, hemmed, long sleeves, and a straight, hemmed bottom. The lounge pants of style 2 feature a self-fabric covered 2-inch-wide elasticized waistband, and hemmed leg openings. The garments will be sold together as a sleepwear pajama set with one price ticket and will feature the “LOFT SLEEP” label sewn onto each garment. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |