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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N318405: The tariff classification of non-threaded fasteners from Italy
| HTS: 7318.24.0000, 3.8%, "Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: non-threaded articles: cotters and cotter pins." |
| Steel retaining rings, known as circlips, made of carbon or stainless steel, that hold various components onto a shaft or in a housing/bore when installed. Once installed the exposed ring acts as a shoulder, which retains the specific components in place. |
| Reason: N/A |
| Ruling Date: April 6, 2021 |
N318406: The tariff classification of an acrylic cosmetic stand from China
| HTS: 3926.90.9985, 5.3%, "Other articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” Secondary classification: 9903.88.15, 7.5%. |
| Item: A cosmetic stand made from acrylic plastic. It is a retail-style display organizer designed to hold lipsticks and other cosmetics and will be used in an e-commerce environment. Per your submission, the dimensions for the stand are 16.4 inches wide by 13.5 inches high by 3.9 inches deep. It includes 72 equally sized compartments and one larger compartment on the side, which runs the height of the stand. This article is designed to be placed on a countertop or table. |
| Reason: N/A |
| Ruling Date: April 6, 2021 |
N318409: The tariff classification of steel brackets from New Zealand
| 8302.41.6080, 3.9%, "Base metal mountings, fittings and similar articles… Other mountings, fittings, and similar articles, and parts thereof: Suitable for buildings: Other: Of iron or steel, of aluminum or of zinc… Other." |
| Item: A galvanized steel bracket with a rubber “dampener.” It is designed to secure interior partition walls in buildings located in areas with high seismic activity. It is comprised of three components. The first component is described as the “base unit bracket” and is screwed into the top of a partition wall head track. The Y-shaped base unit is approximately 8 inches long, 1½ inches wide and bent upward at approximately a 45-degree angle at each end. A rubber “dampener” sits between the “body” and the “arms” of Y-shape. There are 4 screw holes on each of the top ends of the Y-shape, onto which a steel stud (not included) will be attached. The remaining two component are angled brackets that connect the other end of the steel stud to the building structure above. When the three components are connected with a steel stud they will form a brace system to secure and reduce the damage to interior partition walls when an earthquake occurs. |
| Reason: N/A |
| Ruling Date: April 6, 2021 |
N318445: The tariff classification of poly (methyl methacrylate) polymer from Italy
| HTS: 3906.10.0000, 4.5%, "Acrylic polymers in primary forms: poly (methyl methacrylate). |
| Item: An acrylic polymer composed predominantly of poly (methyl methacrylate). The product will be imported in pellet form. The primary use of the product is to produce extruded and injection molded parts. |
| Reason: N/A |
| Ruling Date: April 6, 2021 |
N318481: The tariff classification of footwear from China
| HTS: 6402.99.8061, 90¢/pair + 20%, "Other footwear with outer soles and uppers of rubber or plastics: other footwear: other: other: other: other: valued over $6.50 but not over $12/pair." Secondary classification: 9903.88.15, 7.5%. |
| Item: A women’s, closed-toe/closed-heel, below the ankle, slip-on shoe. The external surface area of the upper is polyurethane rubber/plastic. The upper features elastic gore on the medial side of the vamp, a sewn-in slide fastener on the lateral side of the vamp, and a padded collar. The molded rubber/plastics outer sole has some flocked leather fibers attached to the area in contact with the ground. |
| Reason: The flocking was examined with magnification and found to have a very thin application of fibers that did not obscure the material underneath. The microns-thin application should be treated as a “similar attachment” described in Note 4(a) to Chapter 64 of the Harmonized Tariff Schedule of the United States (HTSUS), and disregarded for tariff purposes pursuant to Note 4(b) to Chapter 64, HTSUS, and General Explanatory Note (C) to Chapter 64, HTSUS. |
| Ruling Date: April 6, 2021 |
N318482: The tariff classification and country of origin of a Twist Drill Bit
| HTS: 8207.50.2055, 5%, "Interchangeable tools for hand tools, whether or not power operated, or for machine-tools (for example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling, turning or screwdriving), including dies for drawing or extruding metal, and rock drilling or earth boring tools; base metal parts thereof: Tools for drilling, other than for rock drilling, and parts thereof: With cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium: Twist drills: Other." |
| Origin: Germany or Thailand. |
| Item: A twist drill bit that will be imported into the United States in various sizes, from 1/16" to 1/2", and made with either round or flat-sided (e.g., hex) shanks. The bit is made of high-speed steel alloy, with cutting parts incorporating by weight more than 0.2% molybdenum and tungsten. The manufacturing process begins with raw material consisting of long, high-speed steel rod that is sourced in China. Tool blanks are then cut from the steel rod and subjected to heat treatment in order to harden the blanks. This is followed by grinding the blank to remove any scale which forms on the blanks during the heat treatment process. After this grinding step, the cylindrical blanks are shipped from China to either Thailand or Germany. In either of these countries, the spiral flutes or grooves along one end of the blank will be machine-grinded into the cylindrical blanks. During the grinding of the flutes, a rough tip is also created in the twist drill bit. |
| Reason: The country of origin of the twist drill bit is the country in which the spiral flutes are formed in the tool blank, thereby creating the tool identified as a twist drill bit. |
| Ruling Date: April 6, 2021 |
N318487: The country of origin of a nozzle deck and a valve deck
| Origin: U.S. and Switzerland |
| Item: A nozzle deck, which functions as the inkjet portion of a print head, and a valve deck, which performs the dual function of directing the flow of ink between the printer and the nozzle deck, and of heating the ink to the appropriate temperature for printing. Both are assembled in China. |
| Reason: The U.S. origin nozzle deck assembly constitutes the essence of the finished nozzle deck. The nozzle assembly performs the essential function of the nozzle deck, which is to ensure that the flow of ink is dispersed into drops. It also accounts for the overwhelming majority of the cost of the finished nozzle deck. The Swiss origin solenoid valves impart the essence of the finished valve deck. The valves direct the flow of ink from the printer tubes into the nozzle deck so that it can be dispersed onto the printing substrate. The function of the solenoid valves remains the same after assembly into the finished valve deck. |
| Ruling Date: April 6, 2021 |
N318554: The tariff classification of dermaplaners from China
| HTS: 8212.10.0000, free, "Razors and razor blades (including razor blade blanks in strips), and base metal parts thereof: [r]azors.” Secondary classification: 9903.88.15, 7.5%. |
| Item: A three-pack of dermaplaners. Each dermaplaner has a plastic handle approximately five inches in length that holds a single stainless steel razor blade. It is typically used to remove light facial hair around the eyebrows. It can also be used to lightly remove facial surface skin to aid in the application of cosmetics. |
| Reason: N/A |
| Ruling Date: April 6, 2021 |
N318577: The tariff classification of Pieri Decobio 320 from France
| HTS: 3824.40.5000, 5%, "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: Prepared additives for cements, mortars or concretes: Other. |
| Item: A substance called Pieri Decobio 320, designed for concrete. It is used on the surface of the formwork to facilitate the even dispersion of the concrete and assist bubble resorption during vibration. |
| Reason: N/A |
| Ruling Date: April 6, 2021 |