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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N351417: The tariff classification of a powder coating from Japan
| HTS: 3824.99.3990, 9903.01.25, free + 10%, “Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Mixtures of two or more inorganic compounds: Other.” |
| Item: The merchandise under review is a powder coating consisting of barium titanate, diniobium pentaoxide, and trontium titanate. |
| Reason: N/A |
| Ruling Date: July 25, 2025 |
N351521: The tariff classification of a gutter shield assembly from Indonesia
| HTS: 7616.99.5190, 9903.85.07; 9903.01.25, 2.5% + 50% + 10%, “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” |
| Item: The item under consideration is described as a gutter shield assembly to be installed onto rain gutters. The assembly consists of a frame of extruded grade 6063-T6 aluminum and grade 316L stainless steel micromesh. |
| Reason: N/A |
| Ruling Date: July 25, 2025 |
N350567: The tariff classification of BHV-1300 and BHV-1310 from China
| HTS: 9817.85.01, free, “Prototypes to be used exclusively for development, testing, product evaluation, or quality control purposes.” |
| Item: BHV-1300 IgG is a bispecific extracellular IgG degrader currently being tested for its efficacy in the treatment of Graves’ Disease. BHV-1310 IgG is also a targeted extracellular protein degrader being tested against multiple autoimmune indications and, in particular, Myasthenia Gravis, or Graves’ Disease. |
| Reason: N/A |
| Ruling Date: July 24, 2025 |
N350620: The country of origin of an electronic pneumatic lumbar support system
| Origin: Indonesia |
| Item: A vehicle seat subassembly, which will be integrated into and fully enclosed in vehicle seats to be installed in certain passenger vehicle models and trims. In the manufacturing process, the plant in South Korea uses the South Korean-origin components and the Chinese-origin components to manufacture the 7CELLs in South Korea. By value, approximately 70% of the 7CELL’s components are sourced from and manufactured by suppliers located in Korea. |
| Reason: A significant number of parts and components are produced in South Korea, the manufacturing process, including the making of PBCAs via SMT process is sufficiently “complex and meaningful”, in which the non-South Korean-origin components are substantially transformed when they are used in the production of the finished products. |
| Ruling Date: July 24, 2025 |
N350643: The country of origin of Nystatin and Triamcinolone Acetonide Ointment, USP
| Origin: India |
| Item: Nystatin and Triamcinolone Acetonide Ointment is a medicinal preparation containing Nystatin (antifungal) and Triamcinolone Acetonide (synthetic corticosteroid), as the active ingredients. It is indicated for the topical treatment of cutaneous candidiasis (yeast infection of the skin). The Ointment contains two active pharmaceutical ingredients (APIs). The Nystatin is made in Italy and the Triamcinolone Acetonide is made in India. In India these two APIs will be mixed with inactive ingredients to produce the final topical ointment in dosage form. |
| Reason: Two separate APIs are mixed to create a fixed combination drug that offers additional medicinal benefits compared to taking each API alone. Nystatin, an antifungal, eliminates the yeast and clears the infection, while the anti-inflammatory action of Triamcinolone Acetonide, a corticosteroid, reduces inflammation, itching, and redness associated with the infection. The mixing of the active ingredients Nystatin (made in Italy) and Triamcinolone A cetonide (made in India) with the inactive ingredients into the final topical ointment in dosage form in India results in a substantial transformation. |
| Ruling Date: July 24, 2025 |
N350729: The eligibility of long term hemodialysis catheters under the Nairobi Protocol treatment from Mexico
| Nairobi Eligibility: Yes |
| Item: Catheters designed specifically for use in patients with chronic kidney disease requiring ongoing hemodialysis. These devices are unsuitable for temporary use in acute or transient renal failure cases and are labeled explicitly for hemodialysis access and have no viable off-label or alternative application. The devices are sold only to hospitals, nephrologists, and dialysis clinics and distributed through medical device channels exclusively for ESRD treatment. |
| Reason: N/A |
| Ruling Date: July 24, 2025 |
N350797: The tariff classification and status under the Dominican Republic-Central America-United States Free Trade Agreement (DR-CAFTA) of a men’s lab coat
| HTS: 6211.33.9058, 9903.01.25, 16% + 10%, “Track suits, ski-suits and swimwear; other garments: Other garments, men’s or boys’: Of man-made fibers: Other: Jackets and jacket-type garments excluded from heading 6201.” |
| DR-CAFTA Eligibility: No |
| Item: A lab coat constructed from 63% nylon, 26% polyester, and 11% spandex woven fabric. It is cut, sewn, and assembled in El Salvador from fabric of Taiwanese origin, and the finished garment will be exported directly from El Salvador to the United States. |
| Reason: The fabric is produced in Taiwan, the garment is not wholly obtained or produced within the CAFTA-DR territory, nor is it produced within the CAFTA-DR territory exclusively from originating materials. |
| Ruling Date: July 24, 2025 |
N350849: The country of absorbent puppy pads
| Origin: Malaysia |
| Item: The product under consideration is absorbent puppy pads. The pads are constructed of multiple layers of functional materials for the purpose of absorbing pet waste and protecting floors or other surfaces. The polyethylene sheet, tissue paper, nonwoven polypropylene sheet, and glue are manufactured in China, the SAP is manufactured in Japan, and the fluffy pulp is manufactured in the United States. All of the components are shipped to Malaysia, where they are cut, positioned (or spread) in layers, embossed, glued together, compressed, folded, and packaged. |
| Reason: The country of origin of the pads is the country where the pads are manufactured from the component materials. |
| Ruling Date: July 24, 2025 |
N350937: The country of origin of wired earbuds
| Origin: Philippines |
| Item: The items concerned are USB-C wired earbuds, which are manufactured from components sourced from the Philippines and China. The actual manufacturing/assembly steps are undertaken in the Philippines. |
| Reason: The manufacturing processes that take place in the Philippines are both meaningful and complex, resulting in the creation of USB-C wired earbuds. |
| Ruling Date: July 24, 2025 |
N350967: The country of origin of wired earphones
| Origin: Philippines |
| Item: The items concerned are 3.5mm stereo wired earphones, which are manufactured from components sourced from the Philippines and China. The actual manufacturing/assembly steps are undertaken in the Philippines. |
| Reason: The manufacturing processes that takes place in the Philippines are both meaningful and complex, resulting in the creation of the 3.5mm stereo wired earphone. |
| Ruling Date: July 24, 2025 |