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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N351059: The tariff classification of printed polyethylene film from France
| HTS: 3920.10.0000, 9903.01.25, 4.2% + 10%, “other plates, sheets, film, foil and strip, of plastics, noncellular and not reinforced, laminated, supported or similarly combined with other materials: of polymers of ethylene.” |
| Item: A flexible printed plastic packaging film composed of 4 layers: 12-micron polyethylene terephthalate (PET), 12.5 microns metallized oriented polypropylene, 12-micron PET and 75-micron polyethylene. The polypropylene layer is metallized with aluminum via vacuum deposition. The film is printed with product information and will be used to manufacture single-use cosmetic sampling sachets. |
| Reason: N/A |
| Ruling Date: July 29, 2025 |
N351170: The tariff classification of a medical instrument from China
| HTS: 9018.90.8000, 9903.01.24; 9903.01.25, free + 20% + 10%, “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences … parts and accessories thereof: [o]ther instruments and appliances and parts and accessories thereof: [o]ther: [o]ther.” |
| Item: The PessaryAssistant is a handheld medical tool constructed of medical-grade polypropylene plastic. It is designed to assist with the placement and removal of vaginal pessaries, which are used in the treatment of pelvic organ prolapse and urinary continence. |
| Reason: N/A |
| Ruling Date: July 29, 2025 |
N351198: The tariff classification of piano overlays from China
| HTS: 4911.99.6000, 9903.01.22; 9903.01.31; 9903.88.15, free + 7.5%, “Other printed matter: Other: Other: Other: Printed on paper in whole or in part by a lithographic process.” |
| Item: The item under consideration is printed piano overlays. The overlays are constructed of thick paperboard that has been printed lithographically with keys, note names, and images on one side. The cards are laid on top of a piano keyboard, aligning with the keys, to teach users note names and locations, sight reading, and memorization. |
| Reason: N/A |
| Ruling Date: July 29, 2025 |
N351244: The tariff classification of an analog digital converter from Japan
| HTS: 8543.70.9860, 9903.01.25, 2.6% + 10%, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” |
| Item: The subject device is presented as a small black box with various LED status lights on one side and a USB and specialized connection point designed to accept signals from the chromatography machine on the other. In use, the device is used in scientific applications by accepting results from the chromatography machine in analog form and converting them to digital. |
| Reason: N/A |
| Ruling Date: July 29, 2025 |
N351266: The country of origin of a double flanged wheel hub assembly with tapered roller bearings
| Origin: Thailand |
| Item: The articles under consideration are wheel hub assemblies with tapered roller bearings, which are used in passenger vehicles. The outer rings and spindles are produced from the forging stage in Thailand, while the inner rings (in a rough, semi-manufactured state) are imported from China. The inner rings are precision machined in Thailand by multiple precision turning operations, drilling or tapping, grinding, and super-finishing, to create a finished product. |
| Reason: The inner ring of Chinese origin and the outer ring of Thai origin are transformed into races with precision raceways in Thailand. |
| Ruling Date: July 29, 2025 |
N351331: The tariff classification and country of origin of metal furniture
| HTS: 9403.20.0050, 9903.81.91; 9903.01.25, free + 50% + 10%, “Other metal furniture and parts thereof: Other metal furniture: Household: Other: Other.” |
| Origin: Vietnam |
| Item: A powder coated steel metal circular platform with swivel casters that is for the display and movement of potted plants. The steel sheet metal and the caster components will be sourced in China. The steel sheet metal will be shipped and exported to Vietnam for manufacture and then to Cambodia for finishing operations. The Chinese caster components will be exported to Cambodia for assembly. |
| Reason: The Chinese steel sheets lose their identity during manufacture and undergo a substantial transformation in Vietnam. The symmetrical geometric cutting, punching, and stamping operations performed in Vietnam results in an article that has undergone a change in commercial designation or identity, fundamental character, or commercial use. Furthermore, the Vietnamese manufacturing operations performed constitutes more than minor processing when compared to the assembly and finishing operations performed in Cambodia. |
| Ruling Date: July 29, 2025 |
N351349: The country of origin of water pumps
| Origin: Vietnam |
| Item: Water pumps designed to be used in the cooling system of a motor vehicle. Once powered by the internal combustion engine, the water pumps circulate fluid to maintain the temperature of the engine and prevent overheating. In the four manufacturing scenarios, the final assembly of the water pumps occurs in Vietnam using components that are sourced from China and Vietnam. |
| Reason: The final assembly processes completed in the four scenarios are rather simple and do not constitute a substantial transformation. Pressing components into the housing is not complex. The origin of the impeller determines the origin, as it is the essential component of the water pump. It provides the force necessary to displace fluid. Therefore, as the country of origin of the impeller is Vietnam, the country of origin of the water pumps is Vietnam. |
| Ruling Date: July 29, 2025 |
N351402: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: The merchandise under consideration is described as five models of a fiber optic patch cord assembly, which consist of a fiber optic core, which consists of multiple optical fibers depending on the model number. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The manufacturing process for all five parts is substantially similar and begins with the creation of the optical fiber in the United States. |
| Reason: The fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores. |
| Ruling Date: July 29, 2025 |
N351406: The tariff classification of costumes 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 Giant Evil Eye, which consists of a long-sleeved robe and a hooded mask depicting a large red eye with a vertical slit-shaped pupil, and features a neck and deep back opening with large, visible, loose overlock stitching. The back opening is closed with a single, small tab of hook and loop fastener. The sleeves and hem bottom have raw, unfinished, jagged cut edges giving a tattered appearance. |
| Reason: The flimsy man-made knitted textile robe provides the essential character of the set. |
| Ruling Date: July 29, 2025 |
N351411: The tariff classification of ball bearings from Indonesia
| HTS: 8482.10.5044, 9903.01.25, 9% + 10%, “Ball or roller bearings, and parts thereof: Other: Radial bearings: Single row bearings: Other bearings, having an outside diameter of: 9 mm and over but not over 30 mm.” |
| Item: The bearings are radial ball bearings that feature an outside diameter that measures 15 or 19 millimeters. The deep-groove single row bearings consist of steel races, steel balls incorporated into a polyamide resin cage, and custom-ordered rubber seals. The bearings are intended to be used in portable oxygen concentrators, specifically the Rove 4 and Rove 6 portable oxygen concentrators. |
| Reason: N/A |
| Ruling Date: July 29, 2025 |