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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N351425: The country of origin of a stabilizer link assembly. Correction to Ruling Number N350324
| Origin: Thailand |
| Item: The article under consideration is a Stabilizer Link Assembly, which is a component of an automotive suspension system. The stabilizer link connects the suspension system to the body for flexibility through joints and/or bushings to effectively absorb shocks and vibrations caused by uneven roads. The stud blank from steel forging and a steel bar for the link housing are sourced from China and imported into Thailand for further processing. |
| Reason: The main components of the stabilizer link, which are the ball stud and the link housing, are substantially transformed into new and different articles as a result of manufacturing processes in Thailand. |
| Ruling Date: July 29, 2025 |
N351460: The country of origin of a door latch for a front-loading dryer
| Origin: Thailand and China |
| Item: The product in question is a door latch, for a front-loading dryer. This article is used in the drying machine’s door lock system and is comprised of a specially shaped plastic housing, lever, and a metal spring. The door latch will be produced in two countries, China and Thailand, under two production scenarios. |
| Reason: For scenario 1, the components that impart the essence of the door latch, i.e., the lever and housing, are produced through injection molding in Thailand. The formation of these components from raw Chinese resin pellets substantially transforms the pellets into components of Thai origin. For scenario 2, the simple assembly operations in Thailand do not substantially transform the fully formed Chinese components. |
| Ruling Date: July 29, 2025 |
N350768: The tariff classification, country of origin, marking and eligibility for preferential tariff treatment under the US-Korea Free Trade Agreement of a prepared vegetable from China
| HTS: 2005.99.9700, 9903.01.24; 9903.01.25; 9903.88.03, 11.2% + 20% + 10% + 25%, “other vegetables prepared or preserved otherwise than by vinegar or acetic acid, not frozen, other than products of heading 2006 … other vegetables and mixtures of vegetables ... other …other.” |
| Origin: China |
| UKFTA Eligibility: Yes |
| Item: The subject merchandise is described as Kimchi which consists of oval-shaped napa cabbage with a red and spicy seasoning carefully worked into each leaf, allowing the flavors to fully meld. The product is manufactured in South Korea using China-origin cabbage. |
| Reason: The manufacturing processes performed in South Korea would not effect a substantial transformation. In short, the process begins with cabbage and ends with cabbage. Accordingly, the kimchi will be considered a product of the country in which the cabbage is grown and harvested, which in this case is China. |
| Ruling Date: July 28, 2025 |
N350779: The tariff classification of a wrist pouch from India
| HTS: 4202.92.9100, 9903.01.25, 17.6% + 10%, “other containers and cases, with outer surface of sheeting of plastic or of textile materials, other, other, with outer surface of textile materials, of man-made fibers (except jewelry boxes of a kind normally sold at retail with their contents).” |
| Item: The article is a zippered pouch designed to be worn around the wrist. It has one zippered compartment and is constructed of man-made textile material. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N350801: The tariff classification of a plastic automotive body trim piece from South Korea
| HTS: 3926.30.5000, 9903.01.25, 5.3% + 10%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [f]ittings for furniture, coachwork or the like: [o]ther.” |
| Item: The product under consideration is described as the “UPR COVER-FR CONSOLE,” which is a plastic console cover installed between the driver and passenger seats in a vehicle. This will not serve as a mounting for the cup holders or wireless charging pad but will merely function as a cover for the console frame. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N350924: The tariff classification of a metal container from Canada
| HTS: 7309.00.0030, 9903.81.90; 9903.01.25, free + 50% + 10%, “Reservoirs, tanks, vats and similar containers for any material (other than compressed or liquefied gas), of iron or steel, of a capacity exceeding 300 liters, whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment: Tanks.” |
| Item: A10-gauge 3/16” carbon steel intermediate bulk container (IBC) for the storage and transport of goods. The container will be used in the petroleum refining, gas processing & petrochemical manufacturing industries for the storage and transport of fresh, spent, and precious metal catalysts. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N350933: The tariff classification of a seat from China
| HTS: 9401.79.0025, 9903.01.24; 9903.01.25; 9903.88.04, free + 20% + 10% + 25%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with metal frames: Other: Other: Outdoor: Other: Household.” |
| Item: “Water Lilies Decorative Garden Stool,” is a welded metal frame seat constructed of 100% percent recycled aluminum. The seat contains no upholstery, no cushions, no backrest, and no armrests. Seating is provided for a single individual. The stool seat depicts floral water lilies located throughout all four sides of the seat. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N350935: The tariff classification of plastic zipper tape from Japan and Thailand
| HTS: 3926.90.9989, 9903.01.25, 5.3% + 10%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.” |
| Item: The product under consideration is described as a PLALOC™ zipper. It is a press-to-close fastener designed for flexible packaging such as plastic bags. It does not include a slider. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N350956: The tariff classification and eligibility under the United States-Mexico-Canada Agreement (USMCA) for a Chocolate Preparation
| HTS: 1806.20.5000, 4.3%, “Chocolate and other food preparations containing cocoa: Other preparations in blocks, slabs or bars, weighing more than 2 kg or in liquid, paste, powder, granular or other bulk form in containers or immediate packings, of a content exceeding 2 kg: Preparations consisting wholly of ground cocoa beans, with or without added cocoa fat, flavoring or emulsifying agents, and containing not more than 32 percent by weight of butterfat or other milk solids and not more than 60 percent by weight of sugar: Other: Other.” |
| USMCA Eligibility: Yes |
| Item: The subject merchandise is described as a Chocolate Preparation. The ingredients are said to be 99% chocolate liquor and 1 percent sugar. The chocolate liquor is stated to be manufactured in Ivory Coast, Ghana, Nigeria, Cameroon, Ecuador, Peru, and/or Brazil. The origin of the sugar is not stated. Once produced, the liquor will be exported to Canada for granulated sugar to be added and establish the required 99 to 1% ratio. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |
N350961: The tariff classification of an automobile seat component from South Korea
| HTS: 9401.99.1085, 9903.01.25, free + 10%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of seats of a kind used for motor vehicles: Other.” |
| Item: The “Seat Armrest Assembly,” is a composite seat component constructed of aluminum metal, polyurethane foam, and pre-cut synthetic leather with stitched seams that will be installed adjacent to the driver and front passenger automobile seat of motor vehicles according to Original Equipment Manufacturer (OEM) specifications. |
| Reason: N/A |
| Ruling Date: July 28, 2025 |