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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N350592: Classification and country of origin determination for an unfinished belt
| HTS: 6217.10.9530, 9903.01.25, 14.6% + 10%, “Other made-up clothing accessories; parts of garments or of clothing accessories, other than those of heading 6212: Accessories: Other: Other: Of man-made fibers.” |
| Origin: Cambodia |
| Item: Two unfinished unisex fashion belts. The strap, that encircles the waist, is constructed from 100% polyester narrow woven fabric. The ratchet strap is constructed from 100% polyurethane material. The unfinished belts do not contain a buckle at the time of importation. The manufacturing operations are as follows: Unfinished belt – Style 1: The embroidered polyester woven fabric is manufactured and cut to length in China or in Cambodia. The ratchet strap component is manufactured in Cambodia and sewn/attached to one end of the embroidered polyester strap in Cambodia. A buckle will be added after importation into the United States. Unfinished belt – Style 2: The polyester woven fabric and polyester ribbon are manufactured and cut to length in China or Cambodia. A ratchet strap is manufactured in Cambodia and sewn/attached to one end of the ornamented polyester strap in Cambodia. A buckle will be added after importation into 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, Cambodia. |
| Ruling Date: July 16, 2025 |
N350618: The tariff classification of an acrylic painting from India
| HTS: 9701.91.0000, 9903.01.31, free, “Painting, drawings and pastels, executed entirely by hand, other than drawings of heading 4906 and other than hand-painted or hand-decorated manufacture articles; collages, mosaics and similar decorative plaques: Other: Paintings, drawings, and pastels.” |
| Item: The “Golden Nature” is a framed acrylic painting by artist Parbbonni Bhowmik that is described as an abstract image of a sunlit forest on a misty morning. The painting is composed of layers of different shades of green, white, and black blended with gold leaf. The piece is her work of art created with acrylic paints on stretched cotton canvas, mounted on a black synthetic plastic resin frame, and the piece bears the date and her signature on the reverse of the canvas. Furthermore, (1) the piece took approximately 15-18 hours to create, (2) the piece is an original and the artist exercised her own aesthetic imagination and conception in creating the piece, (3) “…the entire surface area of the canvas has been materially impacted with hand-applied brush strokes, palette knife work, and texture layering,” and (4) at no time during the creation of each piece was an electromechanical process incorporated. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350633: The tariff classification of a surgical instrument from an unidentified country
| HTS: 9018.90.8000, 9903.01.24; 9903.01.25, free + 20% + 10%, "'other' instruments and apparatus used in medical, surgical, dental, or veterinary sciences, and parts and accessories thereof." |
| Item: A surgical wire cutter used in orthopedic surgeries. It is made primarily of stainless steel with tungsten carbide cutting edges and does not contain rubber, plastic, or foam grip material. It is designed to be sterilized in an autoclave after every use. During a surgical procedure, pin or Kirchner wire is inserted into the bone of a patient in order to hold the bone in position. The cutter is used during the procedure to remove excess wire and pin. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350642: The tariff classification of sensors from China
| HTS: (Senstick SSM40 and KARE+ 3-in-1 sensor) 9025.80.1000, 9903.01.24, 9903.01.25, 9903.88.02, 1.7% + 20% + 10% + 25%, “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: Other instruments: Electrical.” (LHT65N-VIB) 9031.80.8085, 9903.01.24, 9903.01.25, free + 20% + 10%, “Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other.” (RB11E) 9027.50.4050, 9903.01.24, 9903.01.25, free + 20% + 10%:, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Photometers.” (Strips Multi-sensor +Guard sensor) 9025.19.8085, 9903.01.24, 9903.01.25, 9903.88.02, free + 20% + 10% + 25%, “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: Thermometers and pyrometers, not combined with other instruments: Other: Other: Other: Other.” |
| Item: The first item under consideration is the Senstick SSM40, which is a LoRaWAN-based soil moisture sensor designed to monitor volumetric water content in soil. The SSM40 generates variable electrical signals corresponding to the Volumetric Water Content (VWC) of the soil, ranging from 0% to 100%. The second item under consideration is the KARE+ 3-in-1 sensor, which is designed to monitor indoor environmental conditions. It integrates three key sensing functions including smoke detection, temperature measurement, and humidity measurement. The third item under consideration is the LHT65N-VIB, which is a LoRaWAN-enabled vibration sensor used to detect and measure vibrations, shocks, or accelerations of an object in real time. It is typically deployed for machine monitoring while detecting abnormal vibration patterns to predict mechanical failure, pump monitoring by notifying maintenance teams when unexpected motion occurs, and water leak detection when used in combination with environmental clues or sudden vibrations (e.g., pipe bursts). The fourth item under consideration is the RB11E, which is a multi-functional LoRaWAN sensor designed for indoor environmental monitoring. It combines occupancy detection, temperature sensing, and light level monitoring in a single compact device. The sensor can be used to detect human presence to automate lighting and HVAC systems, trigger systems based on room usage to reduce power waste, and alert if motion is detected during scheduled non-occupancy hours. The fifth item under consideration is the Strips Multi-sensor +Guard, an ultra-slim magnetic contact sensor designed for monitoring windows, doors, gates, and valuable items. The sensor can provide building security by detecting unauthorized entry by alerting when doors/windows are opened. It can also automatically disable the HVAC systems when windows are opened, monitor environmental conditions and intrusion in commercial and residential buildings, discreetly monitor access to drawers, cabinets, or even behind picture frames for security in museums, offices, and homes. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350689: The tariff classification of an automated welding system from Canada
| HTS: 8515.31.0000, 9903.01.26, 1.6%, “Electric (including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets; parts thereof: Machines and apparatus for arc (including plasma arc) welding of metals: Fully or partly automatic.” |
| Item: An automated robotic welding cell for structural steel shapes, including W-shaped beams, hollow structural sections, tapered beams, delta beams, panels, and more. The system is available in multiple configurations depending on client requirements. In the configuration presented, the main components will include a Fanuc ARC Mate 120iD/12L welding robot, a moving boom carriage, a vision system, beam rotators, and electrical panels. The Fanuc ARC Mate has a long-reach manipulator arm that is equipped with welding heads for gas metal arc welding or metal-cored arc welding. It is mounted on a moving boom carriage that travels laterally along floor-mounted rails. The beam rotators work in sync with the welding robot and are used to manipulate the workpieces during the welding process. |
| Reason: N/A |
| Ruling Date: July 16, 2025 |
N350719: The country of origin of a utility knife from Vietnam
| Origin: Vietnam |
| Item: A utility knife that features an aluminum handle and a replaceable, disposable steel blade that is retractable into the handle using a sliding control knob. The blades are not permanently attached to the handle. The knife allows the blade to be locked into three different positions and includes three extra utility blades stored in the handle. In Vietnam, raw aluminum blocks from Vietnam, or potentially a different country including China, are diecast to make the left and right sides of the utility knife’s handle body. They are drilled and formed into their final shape and will be ready for assembly. In China, they are polished, powder coat painted, and assembled using small Chinese origin parts including a blade holder, metal switch, and a polyvinyl chloride grip. The trapezoidal utility blade is punched into strips of blade blanks from raw steel in Vietnam. The strips of blades are heated treated in Vietnam and then sharpened in Vietnam. Finally, the sharpened blades are divided from the strips into individual blades in Vietnam before shipment to China. In China, the blades undergo a surface treatment and are then assembled with the blade holder. |
| Reason: Together the handle and blade hold the essential identity of the finished utility knife and that they are not substantially transformed to become new articles having a new name, character, or use after being further processed in China. As such, the country of origin for this utility knife would be Vietnam. |
| Ruling Date: July 16, 2025 |
N350724: The country of origin of door strikes for front-loading dryers
| Origin: Thailand |
| Item: Door strikes (a.k.a. door latch strikes) used in a front-loading drying machine’s door lock system. The door strike is secured to the front of the drying machine’s frame with tabs and fasteners, and acts as a mating part for the machine’s door latch on the dryer door, securing the door in the closed position. The door strikes will be produced in two countries, China and Thailand. Chinese-origin PA66 plastic resin pellets are sent to Thailand where they are dehumidified and then placed into a plastic injection molding machine. The injection molding machine fully forms the complete door strike. The product is then tested and packaged in Thailand. The plastic resin pellets account for 40% of the finished part’s total cost, while the operations in Thailand account for the remaining 60%. |
| Reason: The injection molding of the Chinese resin pellets in Thailand substantially transforms the pellets into door strikes of Thai origin. As such, the country of origin of the door strikes will be Thailand. |
| Ruling Date: July 16, 2025 |
N350750: The country of origin of a spectrophotometer
| Origin: U.S. |
| Item: The item under consideration is the DC1000 spectrophotometer, which is a benchtop instrument designed to measure the intensity of light across a specific range of wavelengths. It is intended to analyze the color and spectral properties of samples in various industries. The DC1000 is made up of several different articles. The first is the SPX-Spectrophotometer Sub-Assembly, which is a U.S.-origin dual beam spectrophotometer assembly capable of splitting light from a sample and reference channels across the visible spectrum. The SPX-Spectrophotometer sub-assembly is solely sourced from the United States where all manufacturing steps including procurement, assembly, testing, packaging, and stocking is performed. The SPX-Spectrophotometer sub-assembly is then shipped to China for further assembly into the final DC1000 machine. The next component is the power supply, which is produced in the United States by a third-party supplier. The final sphere subassembly, also known as an “integrating sphere,” is used to measure the total light power of a source in order to allow illumination or reflection onto an object outside of the sphere. It is a hollow spherical cavity with its interior coated in barium. Other than the barium coating, which is mostly sourced from Italy with a small quantity of purchases coming from Germany or the U.S., the rest of the subassembly is of Chinese origin and assembled in China before further incorporation into the final assembly. All subassemblies are assembled to one another in China. Sub-assembly incorporation of the SPX-Spectrophotometer, final sphere, filter wheel, flash lamp, zoom lens, reference beam, and PCBAs, are generally assembled in China by using benchtop and non-electrical tooling (such as a torque screwdriver, thread-locker, glue, and computers with which to test software) to connect the individual parts of each unit together. |
| Reason: The assembly process performed in China is not complex and does not constitute a substantial transformation. The process predominately involves taking the pre-constructed components and screwing and snapping them into place. The combining of these articles does not create a new and different article of commerce with a name, character, and use distinct from the individual components. Therefore, to determine the origin of the DC1000, it is the origin of the SPX-Spectrophotometer Sub-Assembly and PCBAs which provide the essence of the finished spectrophotometer. These devices include the measuring components necessary for the spectrophotometer to operate. The SPX-Spectrophotometer and PCBAs are manufactured and substantially transformed in the U.S. before being shipped to China. |
| Ruling Date: July 16, 2025 |
N350753: The tariff classification of blood glucose test strips from Taiwan
| 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, with one layer containing a chemical mixture (a reagent). They are designed solely for use by persons with diabetes to monitor their blood glucose levels. 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. Based on the complete chemical breakdown of the blood glucose test strips, the chemical mixtures do not contain antigens or antisera. |
| Reason: The instant blood glucose test 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. Based on the precedents, they qualify for duty-free treatment under subheading 9817.00.96. |
| Ruling Date: July 16, 2025 |
N350754: 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 which are made of different layers, with one layer containing 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. Based on the complete chemical breakdown of the blood glucose test strips, the chemical mixtures do not contain antigens or antisera. |
| Reason: The instant blood glucose test 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. Based on the precedents, they qualify for duty-free treatment under subheading 9817.00.96. |
| Ruling Date: July 16, 2025 |