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.
N351057: Country of Origin Determination for Bicycle Assembled in China with Frame Made in Vietnam
| Origin: Vietnam |
| Item: The item under consideration has been identified as the Troxus Trax LT e-bike. The bike is assembled in China using components manufactured in China and Vietnam. The frame is wholly produced in Vietnam from raw material sourced from China and Vietnam. |
| Reason: The raw aluminum tubing of Chinese and Vietnamese origin undergoes significant manufacturing in Vietnam. The processes -- cutting, shaping, welding, heat-treating, and finishing -- transform the aluminum tubing into a finished bicycle frame with distinct characteristics and function. |
| Ruling Date: July 24, 2025 |
N351064: The country of origin of facial tissue
| Origin: Indonesia |
| Item: The paper product under consideration is packages of "facial tissue." They come in double and triple ply with 1/2 fold. The bulk rolls of facial tissue stock are manufactured in Indonesia and are then sent to China, where the tissue paper is embossed, and cut and folded to length and width. |
| Reason: In China the facial tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting, folding, and packaging. |
| Ruling Date: July 24, 2025 |
N351065: The country of origin of toilet tissue
| Origin: Indonesia |
| Item: The paper product under consideration is packages of "toilet tissue." They come in double and triple ply with 1/2 fold. The bulk rolls of toilet tissue stock are manufactured in Indonesia and are then sent to China, where the tissue paper is unwound, embossed, and cut and folded to length and width. |
| Reason: In China the toilet tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by unwinding, embossing, cutting, folding, and packaging. |
| Ruling Date: July 24, 2025 |
N351066: The country of origin of pocket tissue
| Origin: Indonesia |
| Item: The paper product under consideration are packages of "pocket tissue." They come in double and triple ply with 1/2 fold. The bulk rolls of pocket tissue stock are manufactured in Indonesia and are then sent to China, where the tissue paper is embossed and cut and folded to length and width. |
| Reason: In China the pocket tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting, folding, and packaging. |
| Ruling Date: July 24, 2025 |
N351174: The country of origin of automotive jack stands
| Origin: Thailand |
| Item: The items under consideration are described as powder coated iron and steel jack stands which support the weight of a vehicle after lifting by another device. During use, the user adjusts the height of the jack stand’s ratchet bar to meet the chassis of a raised vehicle. After planning and raw material inspection processes, steel plate from China is cut and stamped to size using steel plate shearing and laser cutting machines to produce the components of the steel base and locking pin. In Thailand, the cast ratchet bar is manufactured and undergoes shot blasting. Also in Thailand, steel components from China are welded to form the structure of the base assembly. Following that, the handle and pawl are assembled, and all components are powder coated. |
| Reason: The totality of manufacturing processes and assembly operations in Thailand substantially transform the constituent components from China and Thailand. Before processing in Thailand, the raw materials and components do not possess the physical characteristics necessary for use as a jack stand. Individually, the raw materials and components are not capable of bearing the weight of a vehicle and maintaining its position by providing an adjustable yet stable base of support. Following the manufacturing operations and assembly in Thailand, the components lose their individual identities and a different article emerges with a new name, character, and use. |
| Ruling Date: July 24, 2025 |
N351220: The tariff classification of the “Fisher-Price® Big Little Feelings® Calm Down Kit” from Mexico
| HTS: (Feelings Book) 4901.99.0092, 9903.01.27, 9903.01.03, free, “Printed books, brochures, leaflets and similar printed matter, whether or not in single sheets: Other: Other: Other: Other: Other: Containing 5 or more pages each, but not more than 48 pages each (excluding covers).” (card) 4901.10.0040, 9903.01.27, 9903.01.03, free, “Printed books, brochures, leaflets and similar printed matter, whether or not in single sheets: In single sheets, whether or not folded: Other.” (toys) 9503.00.0071, 9903.01.01, 9903.01.27, free + 25%, “Tricycles, scooters, pedal cars and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended for use by persons: Under 3 years of age.” |
| Item: The article under consideration is the “Fisher-Price® Big Little Feelings® Calm Down Kit,” consisting of a Fisher-Price® “Feelings See ’n Say” battery operated sound toy, a small “Sun” plush toy, a board book and a “Tips” card. The “Feelings See ’n Say” is a round plastic interactive toy that plays a song or says a phrase when the lever is pulled, and the pointer spins to an image. The “Sun” is a round polyester plush toy measuring approximately 4” in diameter. The “Feelings See ’n Say,” and the plush “Sun” toys are principally designed for the amusement of children 2 years of age and older. The Feelings Book is a children’s book printed on chipboard. The book consists of 14 rigid, printed pages in addition to the covers, which also are printed internally and externally. The “Little Tips for Big Feelings” card is constructed of plastic-covered chipboard and is printed lithographically on both sides with guidance such as “Quick Calm Down Skills” and other instructions for approaching children’s feelings. |
| Reason: Although the toy, “Feelings See ’n Say,” has the same images as those portrayed in the book, and will be packaged and sold together, there is no clear nexus between the two articles which contemplates a use together to amuse. Reading the book is an activity separate from playing with the toy. Therefore, the items are not a set for tariff purposes and will be classified separately. |
| Ruling Date: July 24, 2025 |
N351229: The country of origin of disposable electronic cigarettes
| Origin: Indonesia |
| Item: Five models of disposable electronic cigarettes which are virtually identical in form and function with only minor differences in size and shape. The subject devices are comprised of a heating module within a sealed housing, which also contains the lithium battery and the location for the storage of the substance. There two manufacturing scenarios that cover all five models of electronic cigarettes. In both cases, the manufacturing process begins in Indonesia. In Indonesia, the heating module, which is composed of a heater base, ceramic matrix, and fabric strip, is created by wrapping the ceramic matrix with the fabric strip and then placing this subassembly onto the heater base. Further, in Indonesia the control module is created. This module contains the electrical control elements for the finished device. In scenario 1, the remainder of the steps are completed in Indonesia. In scenario 2, the heating and control modules are sent to China for the rest of the process. |
| Reason: The heating and control modules impart the character as they are the essential electrical components of the devices. Further, any assembly process performed in China in scenario 2 does not substantially transform the components into new and different articles of commerce. |
| Ruling Date: July 24, 2025 |
N351232: The tariff classification of a video magnifier camera from China
| HTS: 8525.89.5050, 9817.00.96, free, “Transmission apparatus for radio broadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras, digital cameras and video camera recorders: Television cameras, digital cameras and video camera recorders: Other: Other: Other.” |
| Item: The merchandise under consideration is the Optaro low-vision video magnifier, which is a full HD camera and a stand that is designed to attach to a smartphone. The Optaro is composed of an integrated camera module, which captures still images and saves the images to the photo library of a smartphone. The Optaro, which is sold by eyecare professionals and entities that service the handicapped, is designed for severely visually impaired people. |
| Reason: N/A |
| Ruling Date: July 24, 2025 |
N351261: The country of origin of a speed sensor assembly
| Origin: Philippines |
| Item: The device is composed of a Hall Effect sensor integrated circuit (IC) that is attached to an electrical distribution and protection PCBA within a plastic enclosure with a connector at one end. The device is used within the transmission of a UTV or ATV in order to detect the speed of the turning gears. The manufacturing process begins with the creation of the Hall Effect IC in the Philippines, which includes the silicon microchip and the magnet assembly. This finished IC is then sent to China where it is soldered to the PCBA and placed within the plastic carrier enclosure, which incorporates the electrical connector. The PCBA is manufactured in China with various resistors, diodes, and capacitors. |
| Reason: The Hall Effect IC imparts the character of the finished device. This IC provides the essential functions of the device as it creates the magnetic and electrical signal, which is the component that senses the appropriate speed. Further, the assembly process performed in China is simple in nature and would not result in a substantial transformation of the individual components into new and different articles of commerce. |
| Ruling Date: July 24, 2025 |
N351293: The tariff classification of blood glucose test strips from Taiwan and 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 Blood Glucose Test Strips and 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. The blood glucose test strip is designed to be inserted into a blood glucose meter. |
| 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. |
| Ruling Date: July 24, 2025 |