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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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.
N350762: The applicability of subheading of subheading 9801.00.10 for a 2025 BMW X4M
| HTS: 9801.00.1065, free, “Products of the United States when returned after having been exported, or any other products when returned within 3 years after having been exported, without having been advanced in value or improved in condition by any process of manufacture or other means while abroad: Articles provided for in chapter 87: Articles provided for in heading 8703.” |
| Item: A 2025 BMW X4 M, which was assembled in March 2025, in Spartanburg, South Carolina, and then exported for sale thru BMW’s Overseas Military Sales Program. Unlike a new vehicle, this vehicle was used as a demonstration model and has approximately 900 miles on the odometer. The vehicle will be imported back into the United States from Kaiserslautern, Germany. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350833: The tariff classification of blood glucose test strips from South Korea
| HTS: 3822.19.0080, 9817.00.96, free, “[d]iagnostic or laboratory reagents on a backing, prepared diagnostic or laboratory reagents whether or not on a backing, whether or not put up in the form of kits, other than those of heading 3006; certified reference materials: [d]iagnostic or laboratory reagents on a backing, prepared diagnostic or laboratory reagents whether or not on a backing, whether or not put up in the form of kits: [o]ther: [o]ther: [o]ther.” |
| Item: Blood glucose test strips made of different layers and one layer contains a chemical mixture (a reagent). They are designed solely for use by persons with diabetes to monitor their blood glucose levels. The blood glucose test strip is designed to be inserted into a blood glucose meter. The user applies a small sample of blood obtained using a lancing device to the test strip. Glucose in the blood sample reacts with the chemical mixture on the test strip. This yields a small electrical current. The blood glucose meter measures this current. It then shows the blood glucose result proportional to the current. |
| Reason: The strips are specially designed for the use or benefit of people with diabetes, enabling them to monitor their blood sugar levels regularly when used with the blood glucose meters. They qualify for duty-free treatment under subheading 9817.00.96. |
| Ruling Date: July 16, 2025 |
N350860: The tariff classification of a decorative aluminum wall hanging from China
| HTS: 8306.29.0000, 9903.01.24; 9903.01.25, free + 20% + 10%, “Bells, gongs and the like, nonelectric, of base metal; statuettes and other ornaments, of base metal; photograph, picture or similar frames, of base metal; mirrors of base metal; and base metal parts thereof: Statuettes and other ornaments, and parts thereof: Other.” |
| Item: A Sun Moon and Stars Wall Plaque, which is a circular aluminum wall hanging depicting a smiling sun in the center, and stars and a quarter moon with a face situated around the sun. It is made of 100% recycled cast aluminum. There is a hole cast on the back to hang the plaque. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350867: The country of origin of a vaporizer subassembly
| Origin: Vietnam |
| Item: The Collector Sub Assembly, which is a component of the finished JUUL 2 Pod vaporizer device. The subject device comprises a resistive heating element and cotton wick encased within a plastic housing. Attached to the plastic housing is a collector, which allows for the e-liquid to flow properly through the finished vaporizer pod. The subject assembly functions as the primary heating element for the vaporizer device. At importation, the subassembly does not contain an e-liquid reservoir or the electrical elements necessary to vaporize the liquid. The manufacturing process begins in Vietnam with the creation of the resistive heating element. The heating element is then sent to China where the cotton wick is inserted within a specialized slot on the side of the element. The element and wick are then encased within the plastic housing, upon which the collector is laser welded. The finished device is then packaged for shipment to the United States. |
| Reason: The resistive heating element created in Vietnam imparts the character of the finished device. Further, the assembly process performed in China is simple in nature and does not substantially transform the element into a new and different article of commerce. |
| Ruling Date: July 16, 2025 |
N350919: The tariff classification of a polyethylene packaging tube from Korea
| HTS: 3923.90.0080, 9903.01.25, 3% + 10%, “articles for the conveyance or packing of goods, of plastics: other: other.” |
| Item: A dropper tube sleeve. The tube is composed of polyethylene. The tube will be imported empty with the bottom unsealed. The tube incorporates a spiral shaped head to allow for the attachment of a lid after importation. After importation the tube will be filled with a cosmetic product and the bottom will be sealed. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350985: The country of origin of rifle stocks
| Origin: Canada |
| Item: Rifle stocks for use with SKS type rifles. The subject rifle stocks are mainly composed of a three-dimensionally (3D) printed polymer stock, a metal folding mechanism assembly, and a pistol grip. The 3D printed polymer stock is the main component which interfaces with the rifle’s firearm components. In total, there are 18 discrete components sourced from Canada, the U.S., and China. In addition, all assembly takes place exclusively in Canada. The breakdown of components is as follows: 1 - 3D printed polymer stock (Canada) 3 - Compression springs (China) 4 - Stainless steel components (China) 1 - Machined steel part (China) 1 - Welded subassembly (China) 7 - Fasteners and hardware elements (Canada) 1 - Pistol grip (U.S.) The production process begins when Canadian or U.S.-sourced polymer is prepared for 3D printing through a drying process. The U.S. origin pistol grip is installed to the underside of the 3D printed polymer stock and checked for fit. After this final assembly step, the rifle stocks are laser-engraved with required logos and serial number and undergo full functional inspection and packaging. |
| Reason: The main component of the subject rifle stocks is the 3D-printed polymer stock which is formed in Canada. It is the component that provides the “chassis” for the rifle’s firearm components to sit in. The 3D printed polymer stock is designed and manufactured with a predetermined physical form dedicated for end use as a rifle stock. After assembly in Canada with components from China and the U.S., the 3D printed polymer stock is not substantially transformed. No article emerges with a new, name, character, and use than which existed prior to the assembly in Canada. |
| Ruling Date: July 16, 2025 |
N351247: The tariff classification of equine exercise machines from China
| HTS: 8479.89.9599, 9903.01.24; 9903.01.25; 9903.88.03, 2.5% + 20% + 10% + 25%, “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” |
| Item: Three models of the Reeds Horse Exercise machine. The machines resemble large human treadmill exercisers. These machines are comprised of a steel “W” (wide flange) beam main frame which supports steel rollers that turn a rubber treadmill track, and sides and handrails of galvanized steel plating and pipe. The rollers are driven by an electric motor coupled to a gearbox driven by a variable frequency drive (VFD), permitting a range of speeds from 0-18 mph. The machines also include a hydraulic pump/motor connected to two hydraulic pistons that raise one end of the machine for inclined exercising. Steel entrance and exit ramps for the machines are included in the importation. The machines include a control box that contains the VFD, start/stop pushbuttons, LCD speed display, and speed and incline selector knobs. The machines weigh approximately 3,600 lbs. and measure 67" (W) x 161" (L) x 85" (H). In operation, a horse handler loads the horse onto the machine’s rubber track, then secures the horse through the bridle to the machine’s rails. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350227: The classification, country of origin, and marking of a Tee Head Bolt Assembly and Mechanical Joint Gasket Pack
| HTS: (Tee Head Bolt with Hex Nut) 7318.15.2095, 9903.01.25, 9903.81.90, free + 10% + 50%, “Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Bolts and bolts and their nuts or washers entered or exported in the same shipment… Having shanks or threads with a diameter of 6 mm or more: Other: Other: Other.” (Mechanical Joint Rubber Gasket) 4016.93.5050, 9903.01.25, 2.5% + 10%, “Other articles of vulcanized rubber other than hard rubber: Gaskets, washers and other seals: Other: Other.” |
| Origin: Malaysia and India |
| Item: A partially threaded 3/4 x 3-1/2 inch (19 mm diameter x 89 inches long) fastener made of low-alloy Corten weathering steel. The Heavy Hex Nut is designed to pair with the Tee Head Bolt and is made of the same low-alloy Corten weathering steel. The Tee Head Bolt and Heavy Hex Nut are both produced from wire rod sourced from Vietnam and China and shipped to Malaysia. In Malaysia, the bolt is cold-forged to the tee-head configuration, threaded and tested. The nut is cold-forged, tapped, and tested. The second item under consideration is described as a Mechanical Joint Gasket Pack (Part No. MGP). The pack includes six of the above-described Tee Head Bolt & Nut Assemblies and one 6-inch Mechanical Joint Rubber Gasket composed of vulcanized styrene butadiene rubber (SBR). The gasket is specially formulated for pressure sealing applications and is made in India. The pack is a pipeline connection kit designed for ductile iron pipe systems. |
| Reason: The wire rod sourced from Vietnam or China undergoes processing in Malaysia that is sufficiently complex and meaningful as to result in a substantial transformation such that the wire rod loses its individual identity and becomes a new article, possessing a new name, character, and use. As such, the country of origin of the Tee Bolt Assemblies is Malaysia. The Mechanical Joint Gasket Pack comprises six of the Tee Bolt Assemblies from Malaysia and one Gasket from India that are packaged together in Malaysia. Simple packaging would not amount to a substantial transformation in which a product with a new name, character, and use is created. Therefore, the articles are not substantially transformed when packaged together as a set. As such, the country of origin of the Tee Bolt Assemblies is Malaysia, and the country of origin of the Gasket is India. |
| Ruling Date: July 15, 2025 |
N350289: The tariff classification and country of origin of a desktop furniture component
| HTS: 9403.99.2080, 9903.01.25, free + 10%, “Other furniture and parts thereof: Parts: Other: Other: Of cane, osier, bamboo or similar materials: Other.” |
| Origin: Vietnam |
| Item: The “Bamboo Desktop” is a 25mm thick +/-0.5mm furniture component constructed of 3 layers of bamboo reeds layered perpendicular to the previous layer of reeds. Predrilled holes and metal thread inserts are located on the underside of the desktop surface. The furniture component will be made available as (1) a rectangular straight edge desktop surface, (2) a rectangular straight edge desktop surface with a concave and convex rim, and (3) a partial rectangular straight edge desktop surface with a partial concave and convex rim. The desktops will be finished with multiple layers of polyurethane, flat packaged for retail sale, and will be ready for installation on a frame when received by the ultimate purchaser. The wood components (bamboo reed panels), and glue for lamination of the bamboo reed panels will be sourced in China. In China, the bamboo will be harvested, cut into strips, dried, pressurized, sorted by quality and color, and pressed glued to create rough edge panels of different lengths, widths, and thickness. Metal thread inserts will be sourced in Malaysia. The furniture components will be shipped and exported to Vietnam. In Vietnam, wood sealers, polyurethane, and staining materials will be locally sourced. In Vietnam, the incomplete and unfinished furniture components will undergo manufacture. |
| Reason: The Chinese and Malaysian components lose their identity during manufacture and undergo a substantial transformation in Vietnam to become complete desktop surfaces, thereby, taking on a new name, character, and use. Furthermore, the manufacturing operations performed in Vietnam constitute more than minor processing and exceed simple assembly. |
| Ruling Date: July 15, 2025 |
N350397: The tariff classification of a Superlok Union from South Korea
| HTS: 7307.29.0090, 9903.81.90; 9903.01.33, 5% + 50%, “tube or pipe fittings (for example, couplings, elbows, sleeves), of iron or steel: other, of stainless steel: other: other.” |
| Item: The Superlok Union, model SU-6. It is manufactured from stainless steel and is composed of four parts: the body, a front ferrule, a back ferrule, and a nut. The ferrules and the nut are found on each side of the body. A metal pipe or tube is connected to each side of the Superlok Union. It allows for installation, removal, and maintenance without cutting or disturbing the pipe system. |
| Reason: N/A |
| Ruling Date: July 15, 2025 |