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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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Export Compliance Daily combines U.S. export control news, foreign border import regulation and policy developments into a single daily information service that reliably informs its trade professional readers about important current issues affecting their operations.

N333737: The tariff classification of a plastic refrigerator storage bin from China

HTS: 3924.10.4000, 3.4%, “Tableware, kitchenware, other household articles and hygienic or toilet articles, of plastics: Tableware and kitchenware: Other.”
Item: A refrigerator storage bin, SKU #35080501. The bin is made of Polyethylene terephthalate (PET) plastic. The item is a rectangular-shaped clear plastic bin with an open top and a textured base. The textured bottom is intended to hold the food items in place. The bin is safe for food contact and is designed to store and organize food items in the refrigerator.
Reason: N/A
Ruling Date: July 11, 2023

N333863: The tariff classification of a temporary tattoo from China

HTS: 4908.90.0000, 9903.88.15, free + 7.5%, “Transfers (decalcomanias): Other.”
Item: A temporary tattoo featuring a Day of the Dead skull design. The transfer will be placed face down on the skin, wet with a sponge, and left to sit for 30 seconds before the backing paper is peeled away, leaving the image on the skin.
Reason: N/A
Ruling Date: July 11, 2023

N333554: The country of origin of a water filtration system

Country of Origin: U.S.
Item: The A.O. Smith Direct Connect Single-Stage Carbon Block Under Sink Water Filtration System, which provides clean water directly from a faucet. The device connects to the cold water line leading to the sink. The system is assembled in China using components manufactured in various countries, including the U.S., Germany, and China. The assembly process involves screwing, gluing and pressing together 11 components during a 10-step process. The assembly process in China starts with the assembly of the system head. This is a 3-step process that involves 6 workers. The second step involves assembling components together to complete the filter cartridge. The components assembled together during this process include the carbon block filter, Emabond, O-rings, cap key, top cap, Neoperl flow control/regulator, bottom cap, and sump. Labels are also applied to the product during this process. This is a 5-step process that involves 5 workers. The final assembly, which involves attaching the system head to the filter cartridge involves 2 workers. This is followed by the final retail packaging of the product.
Reason: The country of origin of the filtration system is where the carbon block is manufactured.
Ruling Date: July 10, 2023

N333593: The tariff classification of aluminum sheet from Turkey, United Arab Emirates, Bahrain, China, Oman, and Malaysia

HTS: 7606.12.3091, 9903.85.01, 9903.88.15, 3%, 10% + 7.5%, "Aluminum plates, sheets and strip, of a thickness exceeding 0.2 mm): rectangular (including square): of aluminum alloys: not clad, with a thickness of 6.3 mm or less: other: heat-treatable industrial alloys of a kind described in statistical note 6 to this chapter."
Item: Aluminum coil for use in the manufacture of gutters. The sheet will be made from either type 3105 or 4107 aluminum alloy and has not been coated or clad. After importation, the sheet will be de-coiled and fed into a machine where it is roll formed into gutters.
Reason: N/A
Ruling Date: July 10, 2023

N333596: The tariff classification of three individual knives and a set including three knives from Japan

HTS: 8211.92.2000, 4.6%, “[k]nives with cutting blades, serrated or not (including pruning knives), other than knives of heading 8208, and blades and other base metal parts thereof: [o]ther: [o]ther knives having fixed blades: [w]ith rubber or plastic handles: [k]itchen and butcher knives.”
Items: Three types of unique kitchen knives and a set consisting of those three specific knives: a gyuto knife, a santoku knife, and a petty knife. The blades are made from molybdenum vanadium steel with a titanium coating. The knives will be made wholly in Japan and will feature handles from resin plastic with a steel end cap. Regarding the fourth item, a set of the three knives listed above, we note the three knives hold the same subheading classification, thus, they would not constitute a “set” for classification purposes.
Reason: N/A
Ruling Date: July 10, 2023

N333648: The tariff classification of a self-propelled multi-use robotic chassis from Austria

HTS: 8704.60.0000, 25%, “Motor vehicles for the transport of goods: Other, with only electric motor for propulsion.”
Item: A self-propelled robotic crawler, which you state is used for multiple purposes including cargo movement, firefighting, and going into locations that would prove hazardous to humans.
Reason: N/A
Ruling Date: July 10, 2023

N333676: The tariff classification of rooftop racks from China

HTS: 8708.29.5160, 9903.88.03, 2.5% + 25%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other.”
Items: (1) A 2-in-1 car rooftop and hitch cargo carrier made of steel. It will be packaged together with a cargo net (made of polypropylene stretch cord) with 12 plastic hooks. The cargo carrier is 90% of the value of the set. (2) A car rooftop cargo basket made of steel. It will be packaged and sold with a polypropylene stretch cord cargo net with 16 plastic hooks. The cargo basket is 88% of the total value. (3) A car rooftop cross bars made of aluminum. It will be packaged together and sold with a 4-pack of lashing straps made of polypropylene webbing with cam buckles. The cross bars are 86% of the value.
Reason: N/A
Ruling Date: July 10, 2023

N333685: The tariff classification of an automotive wire harness from Vietnam

HTS: 8544.30.0000, 5%, “Insulated (including enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not assembled with electric conductors or fitted with connectors: Ignition wiring sets and other wiring sets of a kind used in vehicles, aircraft or ships.”
Items: Five items described as automotive wire harnesses. The harnesses are composed of various insulated electrical wires bundled together into sets and affixed with connectors and terminals at the ends. These harnesses are designed specifically for automotive application and they are used to connect to the electric motors and heating elements within a vehicle seat. The wire harnesses are designed to send electrical signals to the motors in order to adjust the seat positions and operate the heated seat function.
Reason: N/A
Ruling Date: July 10, 2023

N333507: The tariff classification of women’s and girls’ upper body garments from South Korea

HTS: (1), (2), (3) 6106.10.0010, 19.7%, "Women’s or girls’ blouses and shirts, knitted or crocheted: Of cotton: Women’s."
(4), (5) 6106.10.0030, free, “Women’s or girl’s blouses and shirts, knitted or crocheted: Of cotton: Girls’: Other.”
Items: (1) A women’s blouse composed of 60% cotton and 40% modal jersey knit fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from the shoulders to below the waist and features a V-neckline, long sleeves, rib knit cuffs and a curved, hemmed bottom. (2) A women’s blouse composed of 100% cotton jersey knit fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from the shoulders to below the waist and features a round neckline, long hemmed sleeves, and a straight, hemmed bottom. (3) A women’s blouse composed of 100% cotton jersey knit fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting garment extends from the shoulders to below the waist and features a V-neckline, short hemmed sleeves, and a straight, hemmed bottom. (4) A girls’ upper body garment composed of 74% cotton, 26% polyester knit fabric. The outer surface of the garment’s fabric that measures at least 10 or more stitches per linear centimeter measured in both directions. The loose-fitting pieced sweatshirt style garment extends from the shoulders to below the waist and features a rib knit crew neckline, long sleeves with elasticized rib knit cuffs, and an enclosed elasticized rib knit bottom. (5) A girl’s upper body garment composed of 60% cotton and 40% polyester knit fabric. The loose-fitting garment extends from the shoulders to below the waist and features short sleeves and a rib-knit crew neckline.
Reason: N/A
Ruling Date: July 7, 2023

N333699: The tariff classification of the “Go Glam U-Nique Nail Salon” from China

HTS: 9503.00.0073, free, “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: 3 to 12 years of age.”
Item: The "Go Glam U-Nique Nail Salon," comprised of a battery-operated dryer, 4 nail stampers, a sheet of 200 nail stamps/decals, 4 bottles of nail polish, a bottle of clear topcoat, a toe separator, and an instructional pamphlet. The kit enables children to create unique designs, decorate their own nails, and role-play as a professional nail salon operator. The quality of these goods, as well as the manner in which they are put up for sale, indicates their primary use is that of a toy. The salon is principally designed for the amusement of children 8 years of age and older.
Reason: N/A
Ruling Date: July 7, 2023