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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N351388: 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: An adult-size costume identified as Renaissance Tavern Man, which consists of a long-sleeved pullover top, belt and shoulder strap, and features a band collar and a lace-up front closed with a string tie. The long sleeves have raw, unfinished edges and narrow elastic stitched on with a single line of long, loose straight stitching. The flimsy half elastic waist consists of a strip of narrow exposed elastic stitched directly to the back of the top with one row of long, loose straight stitching. Although the band collar is two-ply, the garment is not well-made. |
| Reason: The flimsy man-made knitted textile top provides the essential character of the set. |
| Ruling Date: July 25, 2025 |
N351454: The country of origin marking of duvet inserts, pillows and mattress toppers from Pakistan
| Marking: Unsatisfactory |
| Item: The subject merchandise includes duvet inserts, pillows, and mattress toppers. In each of these country of origin rulings, the outer shell of the good was formed by the fabric-making process in Pakistan; the fabric was cut and assembled into the shell and then stuffed and finished in China. In each case, country of origin was conferred in Pakistan. |
| Reason: The proposed marking of “Fabric Woven in Pakistan, Cut and Sewn in China” would not be acceptable because it merely indicates where the processes occur and not that Pakistan is the origin of the duvet inserts, pillows and mattress toppers. However, “Made in Pakistan,” “Made in Pakistan, Cut and Sewn in China” or “Made in Pakistan, Further Processed in China,” satisfy the marking requirements. |
| Ruling Date: July 25, 2025 |
N350302: The classification and country of origin of golf clubs
| HTS: 9506.31.0000, 9903.01.24; 9903.01.25; 9903.88.15, 4.4% + 20% + 10% + 7.5%, “Articles and equipment for general physical exercise, gymnastics, athletics, other sports or outdoor games… Golf clubs and other golf equipment; parts and accessories thereof: Golf clubs, complete.” |
| Origin: Vietnam and China |
| Item: The manufacturing operations for the golf clubs are as follows: Scenario 1: The club heads are produced in China from either titanium sourced in China, or stainless steel billets sourced from Vietnam or another country in Asia. The graphite shafts are produced in China and the grips, of either rubber or thermoplastic rubber, are produced in either Taiwan or Malaysia. All items are exported to the Dominican Republic, for assembly. In scenario 2, the heads are produced in Vietnam. |
| Reason: In the first scenario, both the golf club heads and the shafts are produced in China. Therefore, the country of origin is China. In the second scenario, the golf club heads are produced in Vietnam and the shafts are produced in China. Therefore, the countries of origin of the golf clubs are Vietnam (for the heads), and China (for the shafts). |
| Ruling Date: July 3, 2025 |
N351466: The tariff classification of cast gold bars from Switzerland
| HTS: 7108.13.5500, 9903.01.25, free + 10%, “Gold (including gold plated with platinum) unwrought or in semimanufactured forms, or in powder form: Nonmonetary: Other semimanufactured forms: Other: Rectangular or near rectangular shapes, containing 99.5 percent or more by weight of gold and not otherwise marked or decorated than with weight, purity, or other identifying information.” |
| Item: The merchandise under consideration is two styles of gold bars designated as “Gold Kilo Bullion Bar” and “100 Oz Bullion Bar.” Both types of bars are used primarily to back contracts on The Commodity Exchange (COMEX), but are also sold to jewelers or industrial consumers for manufacturing purposes. |
| Reason: N/A |
| Ruling Date: July 31, 2025 |
N349663: The tariff classification of seal carriers from South Korea
| HTS: 8708.80.6590, 9903.94.05; 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” |
| Item: The articles under consideration are seal carriers designed for electric vehicles. The seal carriers are coupled at the bottom of the air spring within the vehicle’s air suspension tower. By sealing air, they contribute to maintaining the air suspension system’s pressure and ensuring its normal operation. The seal carriers are made of 100% aluminum alloy. |
| Reason: N/A |
| Ruling Date: July 1, 2025 |
N350685: The tariff classification of disposable adult incontinence underwear from Germany and France
| HTS: 9619.00.1100, 9903.01.25, free + 10%, “Sanitary towels (pads) and tampons, diapers and diaper liners for babies and similar articles, of any material: Of paper pulp.” |
| Item: Adult incontinence products, specifically designed to cater to the needs of adult patients experiencing bladder weakness. The items are disposable and are composed of 70% fluff, 10% super absorbent polymer and 20% nonwoven textiles. |
| Reason: N/A |
| Ruling Date: July 25, 2025 |
N350763: The tariff classification of a coin purse with a keyring from South Korea
| HTS: 4202.32.9300, 9903.01.25, 17.6% + 10%, “... articles of a kind normally carried in the pocket or in the handbag, with outer surface of textile materials: other: of man-made fibers.” |
| Item: The article in question, which you referred to as style “BTS HAT KEYRING,” is a coin purse made up to emulate a hat. It is attached to a keyring. It performs the utilitarian functions of providing storage, protection, portability, and organization to coins, keys, identification, or other similarly sized personal effects. It is constructed of man-made textile material. |
| Reason: N/A |
| Ruling Date: July 25, 2025 |
N350798: The tariff classification and status under the Dominican Republic-Central America-United States Free Trade Agreement (DR-CAFTA) of women’s scrub tops
| HTS: 6206.40.3033, 9903.01.25, 26.9%, “Women’s or girls’ blouses, shirts and shirt-blouses: Of man-made fibers: Other: Other: Other: Women’s: Designed for use in hospitals, clinics, laboratories or contaminated areas.” |
| CAFTA-DR Eligibility: No |
| Item: A woman’s scrub top constructed from 90% polyester and 10% spandex woven fabric. The pullover style garment features a V-neckline, a left chest pocket, short sleeves, side slits, and a hemmed bottom. 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: Because the fabric is produced in Taiwan, the garment is not wholly obtained or produced within the CAFTA-DR territory or produced within the CAFTA-DR territory exclusively from originating materials. |
| Ruling Date: July 25, 2025 |
N350826: The country of origin of water purification and filtration cartridges
| Origin: U.S. |
| Item: The items under consideration are replacement water purification and filtration cartridges each of which houses a proprietary nonwoven filter media, which enables the core water purification functionality by removing submicron biological, chemical, and particulate contaminants. The non-woven electro-adsorptive filter media is manufactured in the United States and requires 60 skilled workers and dedicated industrial equipment to produce. The manufacturing process then shifts to China where the U.S.-origin filter media is pleated into cylindrical form, hot-sealed into pleat packs, and inserted into Chinese produced polypropylene plastic end caps, which are then glued and cured. |
| Reason: The final assembly process in China predominantly involves molding a plastic housing, gluing, and pressing various components into place and does not create a new and different article. Therefore, it is the origin of the non-woven electro-adsorptive filter media, which provides the essential function of the filter. It is the filter media from the United States which requires considerable technical experience and customized equipment to produce and is the item performing the filtering of the water. |
| Ruling Date: July 25, 2025 |
N351218: The tariff classification of clamshell-style food containers from China
| HTS: 6815.99.4170, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Articles of stone or of other mineral substances …not elsewhere specified or included: Other articles: Other: Other: Other.” |
| Item: The merchandise under consideration are four clamshell-style containers consisting of a blend of 60% natural talc and 40% polypropylene by weight, and are designed to hold food for delivery, takeout, and similar services. |
| Reason: The talc component provides the essential character of these containers. |
| Ruling Date: July 25, 2025 |