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.
N350478: Country of origin determination for a plush blanket; 19 CFR 102.21(c)(2); tariff shift
| Origin: China |
| Item: The subject merchandise, “MS Plush Blanket,” is a plush blanket made from a single layer of 100% polyester knit pile fabric. The fabric is either dyed or printed. All four edges are hemmed. The item will be imported and marketed under Mainstays™ and sold in Walmart retail stores and Walmart.com. The manufacturing operations for the plush blanket are as follows: In China, plush fabric is knitted. Plush fabric is dyed or printed. Plush fabric is exported to Vietnam. In Vietnam, Plush fabric is brushed, polished and treated with an anti-pilling chemical. Plush fabric is cut to size and hemmed. Completed blanket is packaged and exported to the U.S. |
| Reason: As the fabric for the plush blanket is formed by the fabric-making process in a single country, that is, China, as per the terms of the tariff shift requirement, country of origin is conferred in China. |
| Ruling Date: July 15, 2025 |
N350479: Country of origin determination for plush blankets; 19 CFR 102.21(c)(2); tariff shift
| Origin: China |
| Item: The subject merchandise, “Warm & Cozy Plush Velvet Blanket and Throw” and “4 in 1 Cozy and Practical Travel Throw,” are plush blankets made from a single layer of 100% polyester knit pile fabric. The fabric is dyed or printed. All four edges are hemmed. The items will be imported and marketed under Mainstays™ and sold at retail in Walmart stores and various online platforms. The manufacturing operations for the plush blankets are as follows: In China, plush fabric is knitted. Plush fabric is exported to Vietnam. In Vietnam, plush fabric is dyed or printed. Plush fabric is brushed, polished and treated with anti-pilling chemical. Plush fabric is cut to size and hemmed. Finished plush blankets are packaged and exported to the United States. |
| Reason: As the fabric for the plush blankets is formed by the fabric making process in a single country, that is, China, as per the terms of the tariff shift requirement, country of origin is conferred in China. |
| Ruling Date: July 15, 2025 |
N350500: The country of origin of a satellite receiver
| Origin: Malaysia |
| Item: The merchandise under consideration is referred to as the “Hopper 3 (Hopper),” which is a satellite receiver with a DVR tuner. The Hopper connects to a smaller receiver through Multimedia over Coax Alliance (MoCA). Moreover, this receiver consists of two main boards (a motherboard with core components and a Wi-Fi Board), two auxiliary boards (the power board and the button board), and other component parts. In Malaysia, the manufacturing of the motherboard printed circuit board assembly (PCBA), which controls all the critical operations, and the Wi-Fi Board, which provides access to the Internet to view Netflix and other streaming services occurs. This process consists of surface mount technology (SMT) and Through-Hole Technology (THT) processes. During these processes, numerous electronic components are permanently mounted onto raw printed circuit boards (PCBs) via soldering techniques, which results in fully functioning Malaysian PCBAs that can receive and process satellite signals. In China, the manufacturing of the power board, the button board, and the box build assembly process occurs. This assembly process involves the assembly of all the PCBAs with the rest of the components, including screwing on the chassis and the rubber feet. Lastly, the completed Hopper is visually inspected for defects. |
| Reason: Based on the facts presented, the motherboard PCBA and the Wi-Fi PCBA that are manufactured in Malaysia provide the primary functionality for the Hopper. The complex SMT manufacturing production of the motherboard PCBA and the Wi-Fi PCBA consists of placing and soldering numerous individual components onto a bare PCB, thereby, creating functional PCBAs that result in a substantial transformation. Further, the assembly process performed in China does not substantially transform the motherboards PCBA and the Wi-Fi board into a new and different article of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the Hopper is considered a product of Malaysia for origin purposes at the time of importation into the United States. |
| Ruling Date: July 15, 2025 |
N350538: Country of origin determination for a mattress topper; 19 CFR 102.21(c)(2); tariff shift
| Origin: Pakistan |
| Item: The subject mattress topper is comprised of a shell of 100% cotton woven fabric and is stuffed with 100 percent polyester fiber. The mattress topper has a four-inch gusset and self-fabric corded piping not exceeding 6.35 millimeters on the edges. The manufacturing operations are as follows: In Pakistan, the cotton shell fabric is woven. The fabric is exported to China. In China, the shell fabric is bleached and dyed. The fabric is cut and assembled by sewing into an unfinished shell. Polyester staple fiber is manufactured. The shell is filled with polyester fiber and sewn closed. The finished mattress topper is packaged and exported to the United States. |
| Reason: As the fabric comprising the mattress topper 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 15, 2025 |
N350539: Country of origin determination for a mattress pad; 19 CFR 102.21(c)(5); last country of assembly
| Origin: China |
| Item: The subject mattress pad is made of three layers: a face fabric of 100% cotton damask striped woven fabric; 100% polyester fiberfill; and a back fabric of 100% cotton jersey knit fabric. The mattress pad includes a cotton jersey knit skirt with a depth of either 11 or 18 inches and a tunneled elasticized edge. The manufacturing operations are as follows: In Pakistan, the face fabric is woven. The fabric is exported to China. In China, the polyester staple fiber is manufactured. The back fabric is knit. Back fabric is laminated to TPU film. Elasticized narrow fabric is formed. The face and back fabrics are bleached and dyed. The fabrics are cut and assembled by sewing. The mattress pad is filled with polyester fiber and sewn closed. The mattress pad is packaged and exported to the United States. |
| Reason: The country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, China. |
| Ruling Date: July 15, 2025 |
N350571: The tariff classification and country of origin of Pet Wipes
| HTS: 3401.19.0000, 9903.01.25, free + 10%, “Soap; organic surface-active products and preparations for use as soap, in the form of bars, cakes, molded pieces or shapes, whether or not containing soap; organic surface-active products and preparations for washing the skin, in the form of liquid or cream and put up for retail sale, whether or not containing soap; paper, wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent: Soap and organic surface-active products and preparations, in the form of bars, cakes, molded pieces or shapes, and paper, wadding, felt and nonwovens, impregnated, coated or covered with soap or detergent: Other.” |
| Origin: South Korea |
| Item: The subject products are described as nonwoven Pet Wipes, available in multiple scents and sizes. In the manufacturing scenario, a concentrated liquid cleaning preparation, consisting of surface-active agents and various other ingredients, will be formulated and produced in South Korea. The cleansing preparation will be sent to China, where it will be diluted and used to impregnate nonwoven wipes of Chinese origin. In China, the impregnated wipes will also be packaged for retail sale. The finished wipes appear to be disposable and will be imported into the United States for retail sale to consumers seeking pet hygiene products. |
| Reason: The liquid cleansing preparation imparts the finished product’s essential character while the nonwoven material serves as the carrier. The liquid cleansing preparation imparts the finished product’s essential character, and the nonwoven material merely serves as the carrier. In China, the dilution and impregnating of the cleaning solution into the Chinese nonwovens, and packaging processes, do not result in a substantial transformation of the concentrated liquid cleansing preparation of South Korean origin. Therefore, the country of origin of the Pet Wipes is South Korea. |
| Ruling Date: July 15, 2025 |
N350586: The tariff classification of mouse and rat traps from China
| HTS: 7323.90.9080, 9903.01.24; 9903.81.90; 9903.88.03, 3.4% + 20% + 50% + 25%, “Table, kitchen or other household articles and parts thereof, of iron or steel; Other: Other: Other: Other. Other.” |
| Item: The merchandise consists of mouse traps, and a rat trap. The mouse and rat traps assist in killing rodents and are designed for household use. Both mouse traps contain a wooden base platform, an iron hammer, an iron catch, an iron holding bar, and a steel spring. The rat trap contains a wooden base platform, an iron hammer, an iron catch, an iron holding bar, and a steel spring. The items are considered composite goods within the meaning of General Rule of Interpretation (GRI) 3. The mouse and rat traps contain a wooden base platform, an iron hammer, an iron catch, an iron holding bar, and a steel spring. The primary functional components of the mouse and rat traps are the iron and steel components, which, when tripped, release the steel spring and iron hammer and traps the rodents |
| Reason: The iron/steel components imparts the essential character of the mouse and rat traps. |
| Ruling Date: July 15, 2025 |
N350596: 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 interior piece that is mounted on the upper portion of the driver’s door trim. This component is intended to enhance the overall appearance and finish of the interior of the vehicle. It does not serve as a structural nor mechanical element. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |
N350597: 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 decorative garnish that is installed on the handle area of the front door inner trim on the driver’s side of a vehicle. This component is intended to enhance the overall appearance and finish of the interior of the vehicle. It does not serve as a structural, electrical, nor mechanical element. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |
N350598: The tariff classification of plastic automotive body trim pieces 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: An interior decorative molding component, designed for installation around the outer edge of the speaker grill on the front door panel of a vehicle. It does not enhance the performance of the speaker, structure nor any mechanical or functional contribution of a vehicle. The item is primarily composed of Acrylonitrile Butadiene Styrene (ABS), and it would be considered an article of plastic for classification purposes. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |