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March 10 CBP Bulletin Proposes to Modify Rulings on Brass Drains, Electronic Drum Kits

In the March 10 Customs Bulletin (Vol. 55, No. 9), CBP published notices that propose to revoke or modify rulings on brass drains and electronic drum kits.

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Comments on Proposals Due April 9

CBP said consideration will be given to any written comments received by April 9 before taking these actions. In addition, any party that has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)

Proposals

CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.

Brass Drains

Item: Brass drains
Current: 7419.99.5010, Free, “other articles of copper, other...brass plumbing goods not elsewhere specified or included.”
Proposed: 7418.20.10, 3%, “Table, kitchen or other household articles and parts thereof, of copper; pot scourers and scouring or polishing pads, gloves and the like, of copper; sanitary ware and parts thereof, of copper: Sanitary ware and parts thereof: Of copper-zinc base alloys (brass).”
Reason: “As the instant drains connect to the home’s water system in order to receive and direct wastewater into a sanitary drainage system, they are within the scope” of the “definitions of sanitary ware and plumbing fixtures,” CBP said.
Proposed for revocation: NY N267667, dated, Aug. 31, 2015; NY N267669, dated, Aug. 31, 2015; NY N262071, dated March 16, 2015; and NY N262072, dated March 9, 2015
Proposed new ruling: HQ H306046

Electronic Drum Kit

Item: Electronic drum kit made of parts from China, Taiwan, and Sweden, and packaged together in Sweden without the need for further processing
Current: A product of China for country of origin marking purposes
Proposed: The country of origin marking is China, Taiwan, and Sweden
Reason: “The electronic drum kit is packaged together in Sweden as an unassembled drum kit without further processing,” CBP said. “These components are not assembled. Mere packaging of components does not substantially transform any of the components. As such, the main components from China, Taiwan, and Sweden are not substantially transformed in Sweden as they do not emerge with a new name, character, and use.”
Proposed for modification: NY N202375, dated Feb. 28, 2012
Proposed new ruling: HQ H309494