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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N351251: The country of origin of Utility Task Vehicles (UTVs)
| Origin: Vietnam |
| Item: The product at issue is a UTV which is a Viper Series electronic fuel injected four-wheel-drive UTV that features an engine displacement of 229cc. The Viper 250R will be produced in Vietnam using imported Chinese raw materials, but all the production steps will take place in Vietnam. |
| Reason: The processes that take place in Vietnam substantially transform the individual components sourced from China into complete UTVs. |
| Ruling Date: July 30, 2025 |
N351337: The tariff classification of air hose reels from Cambodia
| HTS: 3917.39.0020, 9903.01.25, 3.1% + 10%, “tubes, pipes and hoses and fittings therefor (for example, joints, elbows, flanges), of plastics: other tubes pipes and hoses: other: other: of polyvinyl chloride.” |
| Item: A 50-foot single arm retractable air hose reel. The reel is made of steel and includes a spring-loaded auto-rewind reel mechanism, while the hose is constructed predominantly of polyvinyl chloride (PVC) plastic reinforced with braided polyester and features male brass fittings at both ends. The hoses serve to deliver pressurized air from an air compressor to pneumatic hand tools while the reels, which can be mounted to a wall or ceiling, provide storage for the hose. |
| Reason: N/A |
| Ruling Date: July 30, 2025 |
N351344: The tariff classification of Electronic Shelf Label (ESL) Controllers from China or Taiwan
| HTS: 8517.62.0090, 9903.01.32, 9903.01.24, 9903.88.15, free + 20% + 7.5%, “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network)…: Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” |
| Item: The items concerned are referred to as Electronic Shelf Label (ESL) Controllers which are wireless access points (AP). They are responsible for the data transmission and information interaction between an electronic shelf label (i.e. pricing label used to display the price of an item in a store) and a remote computer system that runs the electronic pricing system architecture. |
| Reason: N/A |
| Ruling Date: July 30, 2025 |
N351451: The tariff classification of spray nozzles from Germany
| HTS: 8424.90.9080, 9903.01.25, free + 10%, “Mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders; fire extinguishers, whether or not charged; spray guns and similar appliances; steam or sand blasting machines and similar jet projecting machines; parts thereof: Parts: Other: Other.” |
| Item: The items under consideration are described as Venturi-style spray nozzles, which are used for agricultural spray booms, and allow for a variety of spray range, pattern, and distribution. The nozzles are typically used for the application of pesticides, herbicides and fertilizers. |
| Reason: N/A |
| Ruling Date: July 30, 2025 |
N351495: The tariff classification of metal furniture from India
| HTS: 9403.20.0086, 9903.01.25, free + 10%, “Other furniture and parts thereof: Other metal furniture: Other: Counters, lockers, racks, display cases, shelves, partitions and similar fixtures: Other.” |
| Item: The “Big Ben Bar Watchtower” is a 3-tier iron metal frame display case with a hinged metal door. The display case contains no wood components. The base tier display compartment incorporates 2 wall-mounted wine wire racks for the placement of wine bottles. |
| Reason: N/A |
| Ruling Date: July 30, 2025 |
N351558: The country of origin of booster cables
| Origin: Vietnam |
| Item: The merchandise under consideration is described as vehicle booster cables, which are comprised of a bundle of copper wire affixed at each end with a clamp connector. The cables further range in wire gauge from 2 AWG to 10 AWG. The subject cables are used to connect one vehicle’s battery to another in order to charge those with low power. The manufacturing process for all five models is virtually identical and occurs primarily in Vietnam. |
| Reason: The individual wire conductor is substantially transformed by the processes performed in Vietnam. The bundling and twisting of up to 465 strands of the wire significantly changes the electrical properties and capabilities of the individual strands. Combining this process with the insulation of the completed cable conductor further alters the electrical capabilities, rendering the individual strands as a new and different article of commerce. |
| Ruling Date: July 30, 2025 |
N351631: The country of origin of a cutting chisel
| Origin: Germany |
| Item: The merchandise under consideration is identified as a chisel. The imported tool incorporates two parts: a cold forged steel body and a carbide tip. The chisel is used in underground coal mines on large continuous miner machines. Final manufacturing of the chisel will occur in Germany using parts and components from one or more countries in the European Union (EU) and a Chinese-origin carbide tip. |
| Reason: The tool comprises two components, i.e., a steel body and a carbide tip. The steel body, while cold forged in Italy, undergoes significant machining in Germany. A hole is precision drilled in the top of the body to accommodate the carbide tip. The base of the body is machined to exact specifications so it can fit into the holder on the continuous miner machine. Additionally, the steel body and carbide tip are permanently brazed together in Germany. After completion of the brazing process, the fully formed chisel then undergoes tempering and annealing in an annealing furnace to reduce the likelihood of any stress fractures occurring during use. Considering the totality of the circumstances, it is our view that the steel body and Chinese-origin carbide tip undergo a substantial transformation in Germany. |
| Ruling Date: July 30, 2025 |
N351670: The tariff classification of oil hose reels from China
| HTS: 4009.22.0050, 9903.01.24, 9903.01.25, 9903.88.03, 2.5% + 20% + 10% + 25%, “tubes, pipes and hoses, of vulcanized rubber other than hard rubber, with or without their fittings (for example, joints, elbows, flanges): reinforced or otherwise combined only with metal: with fittings: other.” |
| Item: The product under consideration is an oil hose reel. It consists of an oil hose and a reel. The reel is made of steel, while the hose is constructed acrylonitrile-butadiene rubber (NBR) reinforced with braided steel wire and features fittings composed of zinc plated steel. The hose reels are used in garages, auto shops and construction sites. The hose delivers the oil while the reels, which can be mounted, provide storage for the hose. |
| Reason: N/A |
| Ruling Date: July 30, 2025 |
N339789: The tariff classification and status under the Dominican Republic-Central America-United States Free Trade Agreement (CAFTA-DR) of women’s trousers
| HTS: 6204.69.2810, 9822.05.01; 9903.01.25, 28.6% + 10%, “Women’s or girls’ suits, ensembles, suit-type jackets, blazers, dresses, skirts, divided skirts, trousers, bib and brace overalls, breeches and shorts (other than swimwear): Trousers, bib and brace overalls, breeches and shorts: Of other textile materials: Other: Of artificial fibers: Trousers, breeches and shorts: Other: Trousers and breeches: Women’s.” |
| CAFTA-DR Status: Styles 1 and 2, but not 3. |
| Item: Style 1 is constructed of 77% rayon, 20% nylon, and 3% elastomeric woven fabric. The pull-on trousers feature two faux front pockets, two rear patch pockets, and hemmed leg openings. Style 2 is constructed of 78% rayon, 19% nylon, and 3% elastomeric woven fabric. The pull-on trousers feature two faux front pockets, two rear patch pockets, and hemmed leg openings. Style 3 is constructed of 78% rayon, 19% nylon, and 3% spandex woven fabric. The pull-on trousers feature two faux front pockets, two rear patch pockets, and hemmed leg openings. The items are cut, sewn, and assembled in Guatemala from fabric of Chinese origin, and the finished garments will be exported directly from Guatemala to the United States. |
| Reason: The fabric for styles 1 and 2 conforms to the exact description and specifications set out in short supply number 150. |
| Ruling Date: July 29, 2025 |
N350783: The tariff classification and origin of a purifier bottle from China
| HTS: 8421.21.0000, free + 20% + 10% + 25%, “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.” |
| Origin: China |
| Item: The item under consideration is described as the 24 oz. GeoPress Ti Purifier Bottle. The device is made from CP4 Grade 1 Titanium and is designed to filter and purify water at any freshwater source (lakes, streams, rivers, etc.). Several of the core components including the titanium inner, titanium outer, and silicone one-way valve are all manufactured in China prior to shipping to Mexico for final assembly. |
| Reason: Missing any of these core components would not allow the item to perform the filtering function. The components, while disassembled and requiring a few additional items, are specifically designed to be a press-style filtration system and cannot be used for any other purpose. The titanium components contain the highest cost of the overall filtration system and also contains the shape and size of the finished product. |
| Ruling Date: July 29, 2025 |