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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N350865: The country of origin of a diesel fuel filter
| Origin: Thailand |
| Item: A diesel fuel filter, which is a component of a diesel engine’s fuel system. It is designed to remove contaminants like dirt, water, and other debris from the diesel fuel before it reaches the engine’s sensitive components, such as fuel injectors. The diesel fuel filters are assembled in Thailand using components from Thailand and China. The assembly process occurs in Thailand and includes fifteen individual steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the paper is slit and broken so that it can be rolled onto the center tube. This is followed by adding clamping strips using an automatic clamping machine. Then, the lower cover is filled with glue before being fitted with the paper core. Once complete, the product is sent to the oven for curing. After curing, the upper-end cover is injected with glue and fitted with the paper core before going back to the oven for additional curing. Finally, the product has the code sprayed, laser marked, and then packaged. |
| Reason: The manufacturing and assembly process performed in Thailand is considered complex. Numerous steps are needed to transform the individual components from China into a finished diesel fuel filter in Thailand. |
| Ruling Date: July 22, 2025 |
N350903: The tariff classification of a filter, a valve kit, pump assemblies and a pump cover from China
| HTS: (individual filters) 8421.21.0000, 9903.01.24; 9903.01.25, 9903.88.01, 9817.00.96, free, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” (valve kit) 8481.80.9005, 9903.01.24; 9903.01.25, 9903.88.03, 9817.00.96, 2%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Other: Solenoid valves.” (pump assemblies) 8413.60.0090, 9903.01.24; 9903.01.25, 9903.88.01, 9817.00.96, free, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Other rotary positive displacement pumps: Other: Other.” (pump cover) 8413.91.9096, 9903.01.24; 9903.01.25, 9903.88.01, 9817.00.96, free, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Parts: Of pumps: Other: Other.” |
| Item: The five products at issue are installed in the Tablo Hemodialysis System Console, which provides hemodialysis treatment for individuals with End-Stage Renal Disease (ESRD). The Ultrafilter is a filter that consists of a plastic housing that encases hollow plastic micro-tubes. The Concentrate Routing Valve Kit consists of a valve and components that mount and contribute to the function of the valve, e.g., a mounting bracket, tubing, screws and washers. The Flush Gland Pump Assembly, which delivers dialysate to the user, consists of a gear pump and a motor. The Vane Pump and Motor Assembly which delivers water to the reverse osmosis filtration unit within the console, consists of a pump and a motor. The Blood Pump Cover is used in a rotary peristaltic pump, which circulates blood through the dialyzer and to the patient. |
| Reason: The issue under consideration is whether the aforementioned articles are specially designed and adapted for use in the Tablo console. Based on the information provided, the subject articles are uniquely designed, and feature electrical connections, and in some instances, fluid connections that solely work with the console. Accordingly, we believe the subject articles are exclusively used with the Tablo Hemodialysis System Console and therefore, eligible for secondary classification in subheading 9817.00.96. |
| Ruling Date: July 22, 2025 |
N350920: The country of origin of a green cartridge filter
| Origin: Thailand |
| Item: The item under consideration is described as a green cartridge, which is an engine filter designed to filter metal shavings and sludge, keep the engine oil clean, protect the engine, and remove oxidized carbon deposits and gel-like sediment. The green cartridges are assembled in Thailand using components from Thailand and China. The assembly process occurs in Thailand and includes 14 individual steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the paper is slit and broken so that it can be rolled onto the central tube. This is followed by adding clamping strips using an automatic clamping machine. Then, the lower cover is filled with glue before being fitted with the paper core. Once complete, the product is sent to the oven for curing. After curing, the process shifts to laser cutting of the yellow velvet cotton and the ultrasonic welding of the yellow velvet cotton. Then it goes to a 4/6 hot plate welding machine before the filter element is wound on a winding machine. Next, comes the O-ring assembly, code spraying, and laser marking and, finally, packaging for shipment to the United States. |
| Reason: The manufacturing and assembly process performed in Thailand is considered complex. Numerous steps are needed to transform the individual components from China into a finished green cartridge in Thailand. |
| Ruling Date: July 22, 2025 |
N351068: The tariff classification of aluminum containers for compressed gas from the Republic of Korea
| HTS: 7613.00.0000, 9903.01.25, 5% + 10%, “Aluminum containers for compressed or liquefied gas.” |
| Item: The items under consideration are described as empty aluminum containers for compressed gas for use with air guns and self-contained underwater breathing apparatus (SCUBA). The cylindrical or tubular aluminum containers mainly consist of a grade 6061 aluminum alloy liner that is reinforced with wound carbon fiber and glass fiber. The containers are intended for use with compressed air, oxygen, hydrogen, or nitrogen. In all models, aluminum predominates by weight over carbon and glass fiber. |
| Reason: N/A |
| Ruling Date: July 22, 2025 |
N351081: The country of origin of an automotive air filter
| Origin: China |
| Item: The item under consideration is described as an automotive air filter, which is an automotive component designed to clean the air that enters a vehicle’s engine and cabin. The automotive air filters are assembled in Thailand using components from Thailand and China. The assembly process occurs in Thailand and includes ten steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the paper is folded before glue and metal mesh is added. Then, the PU foam is added and trimmed. Next, the cotton sponge is glued and applied prior to spray coding, plastic sealing, and final packaging. |
| Reason: The manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the Chinese filter paper is the primary filtering component of the finished filter. While the paper is pleated in Thailand and a few other minor components are added, the paper does not become a new article with a new name, character and use. |
| Ruling Date: July 22, 2025 |
N351082: The country of origin of an automotive air conditioning filter
| Origin: China |
| Item: The item under consideration is described as an automotive air conditioning filter, which is a component of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The automotive air conditioning filters are assembled in Thailand using components from Thailand and China. The assembly process occurs in Thailand and includes ten steps. The process starts with the origami, which is made on a reciprocating origami machine. Next, the ultrasonic welding and manual edging and trimming is undertaken. Then, the edges are automatically trimmed and beveled. The back glue is then applied before spraying coding, plastic sealing, and final packaging. |
| Reason: The manufacturing and assembly process performed in Thailand is not considered complex. The Chinese filter paper is the primary filtering component of the finished filter. While the paper is pleated in Thailand and a few other minor components are added, the paper does not become a new article with a new name, character and use. |
| Ruling Date: July 22, 2025 |
N351102: The tariff classification and country of origin of a Paint by Number Kit
| HTS: 3213.10.0000, 9903.01.24; 9903.01.25; 9903.88.03, 6.5% + 20% + 10% + 25%, “Artists’, students’ or signboard painters’ colors, modifying tints, amusement colors and the like, in tablets, tubes, jars, bottles, pans or in similar forms or packings: Colors in sets.” |
| Origin: China and Vietnam |
| Item: Cowboy Boots Paint by Number Kit. The kit includes twelve paint pots in assorted colors, two paint brushes, and a printed cotton canvas with an outline of cowboy boots. The paints and paint brushes will be used by consumers to creatively paint the outlined cowboy boots on the canvas. The paint will be manufactured in China and shipped to Vietnam in drums where the paint pots will be filled. The paint brushes will be manufactured in China and shipped to Vietnam. The cotton canvas will be manufactured and printed in Vietnam. The kit will be assembled, packaged for retail sale, and shipped from Vietnam to the United States. |
| Reason: The essential character is imparted by the paints and paint brushes (colors in sets) as they are indispensable to the product’s primary function and use, which is the activity of painting. The filling of the paint pots, assembly, and packaging processes in Vietnam do not result in a substantial transformation of the Chinese paints and paint brushes. Therefore, the country of origin for the paints and paint brushes is China and the country of origin for the canvas is Vietnam. |
| Ruling Date: July 22, 2025 |
N351121: The tariff classification of a weighted vest from Taiwan
| HTS: 6110.30.3035, 9903.01.25, 32% + 10%, “Sweaters, pullovers, sweatshirts, waistcoats (vests) and similar articles, knitted or crocheted: Of man-made fibers: Other: Other: Other: Vests, other than sweater vests: Women’s or girls’.” |
| Item: The “Sensory Hugs Weighted Vest” is constructed from a breathable 100% polyester knit backing fabric and a middle layer of plastic foam. The outer surface of the garment’s fabric measures more than nine stitches per two centimeters in the direction the stitches were formed. The vest features a round shaped neckline, oversized hemmed sleeve openings secured by hook-and-loop fasteners at the sides and shoulders, interior pockets at the bottom front and back that hold removable weights, side slits, and a hemmed bottom that reaches below the waist. The vest cannot be identified as men’s or boys’, or women’s or girls’, and is considered a unisex garment. |
| Reason: The polyester vest is the component that imparts the essential character of the garment. |
| Ruling Date: July 22, 2025 |
N351123: The tariff classification of pump assemblies from China
| HTS: 8413.50.0050, 9903.01.24; 9903.01.25; 9903.88.01, free + 20% + 10% + 25%, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; parts thereof: Other reciprocating positive displacement pumps: Diaphragm pumps.” |
| Item: Pump assemblies, which are composed of a reciprocating diaphragm pump coupled to an electric motor. The fluid pump, which is primarily constructed of plastic material, features valves, an inlet, an outlet and a pressure switch that shuts off power to the motor once a certain level of pressure is attained. The pump assembly is designed to be mounted onto mobile spraying units used in agricultural applications. |
| Reason: N/A |
| Ruling Date: July 22, 2025 |
N351125: The tariff classification of multifunction contact stun guns from China
| HTS: 9304.00.6000, 9903.01.24; 9903.01.25; 9903.88.15, 5.7% + 20% + 10% + 7.5%, “Other arms (for example, spring, air or gas guns and pistols, truncheons), excluding those of heading 9307: Other.” |
| Item: The items under consideration are described as handheld multifunction contact stun guns intended for non-lethal civilian self-defense. They are constructed from an acrylonitrile butadiene styrene (ABS) plastic body, ergonomic grip, sliding safety switch, and an internal universal serial bus (USB) rechargeable battery. There are four models which offer different functionalities. All models feature a contact-only electric shock stun gun function. Two fixed prongs emit a high voltage electric arc when pressed against an assailant. There are no cartridges, probes, projectiles, compressed gas, or propellants involved. |
| Reason: The contact stun gun component imparts the essential character of the multifunction contact stun guns. |
| Ruling Date: July 22, 2025 |