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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N351305: The country of origin of Dermasil® Daily Face Cream
| Origin: Malaysia or Vietnam |
| Item: The subject product is described as a face cream sold under the brand name Dermasil®, containing the active ingredient dimethicone, enhanced with rose water and witch hazel. The product is designed to hydrate and nourish the skin while providing a gentle toning and balancing effect. Additional ingredients are sourced from various countries and will be sent to either Malaysia or Vietnam. In Malaysia or Vietnam, the ingredients will be weighed, emulsified, homogenized, and blended under controlled conditions to produce a stable bulk using a mixing machine (emulsifier). The bulk formulation will then be sent from Malaysia or Vietnam to China where it will be filled into retail containers, which originate in China. |
| Reason: The production process in Malaysia or Vietnam results in a substantial transformation. |
| Ruling Date: July 24, 2025 |
N351306: The country of origin of Dermasil® Face Serum Oil
| Origin: Malaysia or Vietnam |
| Item: The subject product is described as a facial serum oil sold under the brand name Dermasil®. It is designed for use on the face to smooth and restore skin. The raw materials are sourced from various countries and these ingredients will be sent to either Malaysia or Vietnam. In Malaysia or Vietnam, the ingredients will be weighed, homogenized, and blended under controlled conditions to produce a stable bulk, then combined with high shear mixing operations using a mixing machine. Preservatives and other ingredients will be added in a cooled-down phase. The bulk formulation will then be sent from Malaysia or Vietnam to China where it will be filled into retail containers. All packaging materials (bottles, caps, cartons, and cardboard) originate in China. |
| Reason: The production process in Malaysia or Vietnam results in a substantial transformation. |
| Ruling Date: July 24, 2025 |
N351311: 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: The items in consideration are three types of Blood Glucose Test Strips which are 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. |
| Reason: The 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, HTSUS. |
| Ruling Date: July 24, 2025 |
N351313: The tariff classification of blood glucose monitors from South Korea
| HTS: 9027.89.4530, 9903.01.25; 9817.00.96, free, “Instruments and apparatus for physical or chemical analysis; 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: Other: Other: Electrical: Chemical analysis instruments and apparatus.” |
| Item: The items under consideration are described as blood glucose monitors which are all very similar with only a few additional features such as Bluetooth capability or voice commands. The blood glucose monitors operate by using a disposable blood glucose test strip which is inserted into the blood glucose monitor. The blood glucose monitoring kits contain a standard set of components, which includes a blood glucose monitor, a carrying case, an owner’s guide, and two CR2032 batteries. |
| Reason: The essential character of the blood glucose monitoring kits is imparted by the blood glucose monitor. The kits are specifically designed for use by the handicapped for secondary classification purposes. |
| Ruling Date: July 24, 2025 |
N351314: The tariff classification of blood beta-Ketone test strips from South Korea
| HTS: 3822.19.0080, 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.” |
| Item: The item in consideration is KetoSens blood beta-Ketone Test Strips which are made of different layers and one layer contains a chemical mixture (a reagent). They are designed solely for use by persons with diabetes to measure their blood ketone levels. |
| Reason: N/A |
| Ruling Date: July 24, 2025 |
N351352: The country of origin of Dermasil® Dry Skin Treatment Body Lotion
| Origin: Malaysia or Vietnam |
| Item: Dermasil® Dry Skin Treatment Body Lotion is an over the counter (OTC) body lotion containing the active ingredient dimethicone. It is specially formulated to create a barrier on the skin to lock in moisture and protect against irritation. It contains other ingredients which are sourced from various countries and will be sent to either Malaysia or Vietnam. In Malaysia or Vietnam, the ingredients will be weighed, emulsified, homogenized, and blended under controlled conditions to produce a stable bulk using a mixing machine (emulsifier). This process includes heating oil and water phases separately, then combining with high shear mixing operations. Preservatives and other ingredients will be added in a cooled-down phase. The bulk formulation will then be sent from Malaysia or Vietnam to China where it will be filled into retail containers, which originate in China. |
| Reason: The production process in Malaysia or Vietnam results in a substantial transformation. |
| Ruling Date: July 24, 2025 |
N351393: The country of origin of a USB Cable
| Origin: Taiwan |
| Item: The subject cable consists of a length of insulated conductor with a USB-A style connector at one end and a lightning-style connector at the other. The cable is a passive device used to transmit high-speed data signals between a number of devices, such as computers and smart phones. The manufacturing process begins in Taiwan with a tinned copper wire conductor being extruded, twisted, braided, jacketed and insulated prior to being cut to the desired length. The unfinished cables will be shipped to China for the final manufacturing process. In China, the ends of the cable are prepared and the connectors of Chinese origin are assembled onto each end of the cable. |
| Reason: The Taiwanese conductor wire imparts the character of the finished article as it is the essential electrical component of the cable. The addition of the connectors through a simple assembly process performed in China does not substantially transform the conductor cable into a new and different article of commerce. |
| Ruling Date: July 24, 2025 |
N351404: The tariff classification of a costume from China and Vietnam
| HTS: 9505.90.6000, 9903.01.24; 9903.01.25, free + 20% + 10%, “Festive, carnival or other entertainment articles, including magic tricks, and practical joke articles; parts and accessories thereof: Other: Other.” |
| Item: A toddler-size costume identified as Cutesy Reaper, which consists of a hooded cape, dress, petti skirt, rope belt, and foam scythe, and features raw, jagged cut edges all around. The cape is closed with only a single small patch of hook and loop fastener. |
| Reason: The flimsy man-made knitted textile cape provides the essential character of the set. |
| Ruling Date: July 24, 2025 |
N351422: The tariff classification of a saw tooth and a mulcher tooth from Canada
| HTS: 8208.40.6000, 9903.01.26, 9903.01.10, free + 25%, “knives and cutting blades, for machines or mechanical appliances, and base metal parts thereof: for agricultural, horticultural, or forestry machines, and parts thereof: other.” |
| Item: A beaver style saw tooth and a planer style mulcher tooth which are made of heat-treated high strength steel and incorporate irregularly shaped cutting tips and blades with threaded center holes for mounting. Each tooth will be imported unmounted. The beaver style saw tooth is used on a felling head equipped with a saw disc. The mulching head is used to grind and shred tree trunks and/or entire trees depending on their size. |
| Reason: N/A |
| Ruling Date: July 24, 2025 |
N350527: The tariff classification of Seasoned Frozen Boneless Beef from Mexico
| HTS: (Under Quota) 0202.30.5085, 9903.01.27, 4.4¢/kg, “Meat of bovine animals, frozen: Boneless: Described in additional U.S. note 3 to this chapter and entered pursuant to its provisions: Other: Other.” (Over Quota) 0202.30.8000, 9903.01.01, 9903.01.27, 26.4% + 25%, “Meat of bovine animals, frozen: Boneless: Other.” |
| Item: The first item is boneless beef composed of flat, chuck, eyeround, and topside cuts. It is seasoned with a marinade by an injection process in an agitator tank. The item is placed in non-vacuum sealed packages exceeding 1 kilogram each, and frozen for shipment to the United States. |
| Reason: N/A |
| Ruling Date: July 23, 2025 |