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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N350976: The tariff classification of suspension parts for heavy-duty trucks from Canada
| HTS: 8708.80.6590, 9903.94.05, 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” |
| Item: There are three items at issue in this request, which are described as suspension beams for air suspension systems within heavy-duty trucks. The suspension beams are presented in three different variations which are identified by Part Numbers 056946-000 (Main Support Member), 053874-000 (Hockey Stick), 052376-000 (Walking Stick). All three types of suspension beams are used within the air suspension system to support the weight and load of the truck. Specifically, the leading end of the beam connects to the chassis of the truck, and the middle portion is tied to the axle while the trailing end of the beam is attached to the rubber air spring. The suspension beams work in conjunction with air springs to serve as robust support members for the weight of the truck and payload, while effectively absorbing the shocks and vibrations from the road surface. This integrated approach significantly enhances ride quality while making the truck more adaptable and comfortable across various driving conditions. |
| Reason: The flimsy man-made knitted textile top provides the essential character of the set. |
| Ruling Date: July 28, 2025 |
N351233: The country of origin of wheel hub assemblies
| Origin: Thailand |
| Item: The merchandise under consideration is described as wheel hub assemblies containing ball bearings, which are used in passenger vehicles. There are holes or bolts on the flange end face, which can be directly connected to the wheel rim and support the weight of the vehicle while enabling smooth rotation of the wheels. The manufacturing process begins in Thailand using components sourced from China. Steel balls, cages, sealing rings, and unfinished/rough inner rings are imported into Thailand from China. The inner rings are then further processed by precision turning, drilling, tapping, grinding and super-finishing to create the finished inner rings. Next, the Thai origin spindle, outer ring, and bolts are assembled together with the components from China to create a finished wheel hub assembly. |
| Reason: The final assembly processes that occur for the wheel hub assembly are not complex enough to render a substantial transformation. The processes performed in Thailand do not change the shape, character or predetermined use of the components. |
| Ruling Date: July 28, 2025 |
N351254: The tariff classification of parts of a lawn mower and subassemblies for a lawn mower from China
| HTS: (deck subassembly with powerhead) 8433.11.0010, 9903.01.24; 9903.01.25, 9903.88.15, free + 20% + 10% + 7.5%, “harvesting or threshing machinery, including straw or fodder balers; grass or hay mowers…, parts thereof: mowers for lawns, parks or sports grounds: powered, with the cutting device rotating in a horizontal plane: electric mowers, including battery operated.” (deck subassembly without powerhead) 8433.90.1090, 9903.01.24; 9903.01.25; 9903.88.03, free + 20% + 10% + 25%, “harvesting or threshing machinery, including straw or fodder balers; grass or hay mowers; machines for cleaning, sorting or grading eggs, fruit or other agricultural produce, other than machinery of heading 8437; parts thereof: parts: of mowers for lawns, parks or sports grounds: other.” (wheels) 8433.90.1010, 9903.01.24; 9903.01.25; 9903.88.03, free + 20% + 10% + 25%, “harvesting or threshing machinery, including straw or fodder balers; grass or hay mowers; machines for cleaning, sorting or grading eggs, fruit or other agricultural produce, other than machinery of heading 8437; parts thereof: parts: of mowers for lawns, parks or sports grounds: wheel and tire assemblies.” (blades) 8208.40.3000, 9903.01.24; 9903.01.25; 9903.88.03, free + 20% + 10% + 25%, “knives and cutting blades, for machines or for mechanical appliances, and base metal parts thereof: for agricultural, horticultural or forestry machines, and parts thereof: lawnmower blades.” |
| Item: The products under consideration are various parts and subassemblies used to manufacture an electrically powered walk behind lawn mower. You have stated that they will be imported separately in bulk. After importation, the parts and subassemblies will be placed in inventory where they will be pulled as needed to assemble a finished lawn mower. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N351268: The tariff classification of a thermostat from China
| HTS: 9032.10.0030, 9903.01.24; 9903.01.25; 9903.88.01, 1.7% + 20% + 10% + 25%, “Automatic regulating or controlling instruments and apparatus; parts and accessories thereof: Thermostats: For air conditioning, refrigeration or heating systems: Designed for wall mounting.” |
| Item: The Madoka Remote Controller, which is a wired wall thermostat designed for controlling indoor mini split air conditioning units. The device offers a touch button control and a sleek modern design. The controller provides basic functions such as on/off, set point, mode, target values, fan speed, louvres, filter icon and reset, and error code. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N351335: The country of origin of sputtering targets
| Origin: China |
| Item: The merchandise under consideration is described as an Aluminum Sputtering Target used in physical vapor deposition (PVD) apparatus. The subject target is an aluminum disk with a copper or alloy backplate and machined connection points. There are two manufacturing scenarios, which cover the same process but different country locations. The process begins with raw aluminum being cast into a roll and then cut to a specific disk shape. This disk is then rolled, annealed, and forged through a thermomechanical process. In both scenarios, these steps are completed in China. |
| Reason: The casting and thermomechanical process performed in China, in both scenarios, imparts the item with its desired capabilities. Further, the backplate bonded to the target, either in China or South Korea, is only used as the structural foundation and provides heat dissipation to the target. This is not an essential functional component of the target. The desired properties for the target are added through the process performed in China. |
| Ruling Date: July 28, 2025 |
N351372: The country of origin of fiber optic cables
| Origin: U.S. |
| Item: Two fiber optic cables. The manufacturing process begins with pre-colored, U.S.-origin optical fibers being imported into Finland. For those cables that are comprised of multiple fibers, the fibers are bundled together in the appropriate configuration. Kevlar strength members are then added prior to plastic jacketing being extruded around the core to complete the cable. |
| Reason: The U.S. origin fibers impart the character of the finished articles. Further, any process performed in Finland is simple in nature and does not substantially transform the fibers into new and different articles of commerce. |
| Ruling Date: July 28, 2025 |
N351401: 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 Dark Renaissance Elf, which consists of a pullover dress, corset, and a pair of pointed elf ears, and features a raw, unfinished neck. The neck and waist have exposed elastic stitched on with a single line of long, loose straight stitching. The elbow-length sleeves and hem bottom have raw, jagged cut edges, giving a tattered appearance. The sleeves, also have narrow exposed elastic stitched on with a single line of long, loose straight stitching. |
| Reason: The flimsy man-made knitted textile off-the-shoulder dress provides the essential character of the set. |
| Ruling Date: July 28, 2025 |
N351434: The tariff classification of calcined manganese ore from South Africa, Gabon, or India
| HTS: 2602.00.0060, 9903.01.32, free, “manganese ores and concentrates, including ferruginous manganese ores and concentrates with a manganese content of 20 percent or more, calculated on the dry weight: containing 47% or more by weight of manganese.” |
| Item: The product under consideration is a calcined manganese ore. The mined ore is subjected to a calcining process that concentrates it into calcined manganese ore. The dry weight of manganese in the calcined manganese ore contains at least 48% of manganese on a dry weight basis. After importation, the calcined manganese ore will be further processed into electrolytic manganese dioxide (EMD). |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N351601: The tariff classification of a 1999 Subaru Sambar light truck from Japan
| HTS: 8704.31.0120, 9903.94.04; 9903.01.25, 2.5% + 10%, “Motor vehicles for the transport of goods: Other, with only spark-ignition internal combustion piston engine: G.V.W. not exceeding 5 metric tons: G.V.W. not exceeding 2.5 metric tons.” |
| Item: The item under consideration has been identified as a 1999 Subaru Sambar, a light-duty utility vehicle. The vehicle possesses the following features: 658cc (0.66 L) spark-ignition, internal combustion piston engine “Cab-over" chassis with a driver's cab, Open rear cargo bed Gross Vehicle Weight Rating (GVWR): Approximately 1,200 kg (1.2 metric tons) Age: Over 25 years old |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N351637: The tariff classification of rub rails from Italy
| HTS: 7326.90.8688, 9903.81.90; 9903.01.25, 2.9% + 50% + 10%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The items under consideration are described as rub rails to be installed over the joint between a boat’s deck and hull. The rub rails cover the joint for aesthetic purposes and protect the boat by absorbing impacts with other objects. The rub rails consist of a polyvinyl chloride (PVC) plastic base and a C-shaped grade 316 stainless steel profile with a core of PVC. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |