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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N350963: The country of origin of selector switches for washing machines
| Origin: China and Thailand |
| Item: A selector switch for use in a washing machine and is comprised of a printed circuit board assembly (PCBA), upon which is a cam assembly, both enclosed within a plastic housing. There are two proposed manufacturing scenarios. In the first scenario, the PCBA, cam assembly, plastic housing, connector and retainer are all manufactured in China. The Chinese components are then sent to Thailand where the cam is assembled with the plastic housing, the PCBA is added and multiple switches are assembled into one piece. The finished device is then tested and packaged for shipment to the United States. In the second scenario, the PCBA is manufactured in Thailand. The cam assembly, plastic housing, connector and retainer are all manufactured in China. The Chinese components are then sent to Thailand where the Chinese cam assembly is inserted into the Chinese housing and the PCBA from Thailand is added. Multiple switches are assembled into one piece in Thailand. The finished device is then tested and packaged for shipment to the United States. |
| Reason: In scenario 1, the Chinese PCBA, which is incorporated into the plastic housing, and cam impart the character of the finished device. Further, the assembly process performed in Thailand is simple in nature and does not substantially transform the PCBA or other Chinese components into new and different article of commerce. Regarding scenario 2, the PCBA originating from Thailand, which is incorporated into the plastic housing, and cam impart the character of the finished device. Further, the assembly process performed in Thailand is simple in nature. Based on the facts presented, the country of origin of the washing machine selector switch for scenario 1 is China and scenario 2 is Thailand. |
| Ruling Date: July 17, 2025 |
N351067: The tariff classification of a bicycle work stand from China
| HTS: 7616.99.5190, 9903.01.24; 9903.85.07; 9903.01.25; 9903.88.03, 2.5% + 20% + 10% + 25% + 50%, “Other articles of aluminum: Other: Other: Other: Other: Other: Other.” |
| Item: A foldable aluminum bicycle work stand which will be used in bicycle repair shops or for personal bicycle repair and maintenance work. The bicycle stand is primarily composed of a vertical, telescoping pole. The pole is supported by two shorter aluminum legs that extend laterally to form a base. At the top of the pole sits an extending arm with a locking 360-degree swiveling clamp that attaches to a bicycle frame to securely hold it in place. Additionally, a tray extends from the vertical pole for a user to place and temporarily store tools or other objects during use. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N351130: The tariff classification of a graphite pencil set from China
| HTS: 9608.40.8000, 9903.01.24; 9903.01.25; 9903.88.15, free + 20% + 10% + 7.5%, “Ball point pens; felt tipped and other porous-tipped pens and markers; fountain pens, stylograph pens and other pens; duplicating styli; propelling or sliding pencils (for example, mechanical pencils); pen-holders, pencil-holders and similar holders; part (including caps and clips) of the foregoing articles, other than those of heading 9609: Propelling or sliding pencils (for example, mechanical pencils): Other.” |
| Item: The article is the “Write On”: Graphite pencils and eraser, item number 128-192. The three-piece set consists of two graphite pencils and one eraser. The items will be packaged in a retail box and sold and marketed as a set. The graphite pencils and eraser will be used for note-taking and sketching. The product is intended for ages 12 and up. The pencils comprise a plastic barrel with a plastic grip, a metal nib with a graphite tip, and a plastic cap. Each pencil features a point graphite lead. The lead tips are encased in a nib piece that screws onto the end of the empty hallow plastic barrels. The eraser is an oval shaped, two-color eraser. The “Write On”: Graphite pencils and eraser is a composite good that includes two pencils and one eraser. |
| Reason: The essential character of this set is imparted by the pencils, which predominate both in use and bulk. |
| Ruling Date: July 17, 2025 |
N351155: The tariff classification of a “Girl Doll” from China
| HTS: 9503.00.0090, 9903.01.24; 9903.01.25, free + 20% + 10%, “Tricycles, scooters, pedal cars and similar wheeled toys … dolls, other toys … puzzles of all kinds; parts and accessories thereof … Other.” |
| Item: The item is a decorative rag doll measuring 18.5 inches in length. The doll has white braided pigtails and is wearing a white fuzzy hat, white fuzzy sweater, a gold shimmering tutu dress and gold fabric booties. The body is composed of fabric and polyester fiberfill with a weighted bottom section containing gravel. The weight from the gravel provides the stability needed for the doll to sit on a shelf. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N351160: The tariff classification of scoops from China
| HTS: 8205.59.5560, 9903.01.24; 9903.01.25; 9903.88.03, 5.3% + 20% + 10% + 25%, “handtools (including glass cutters) not elsewhere specified or included; blow torches and similar self-contained torches; vises, clamps and the like, other than accessories for and parts of machine tools or water-jet cutting machines; anvils; portable forges; hand- or pedal-operated grinding wheels with frameworks; base metal parts thereof: other handtools (including glass cutters) and parts thereof: other: other: of iron or steel: other: other (including parts).” |
| Item: The items under consideration are identified as industrial scoops and pharma scoops. Both are made of 18-gauge type 304 stainless steel. The bowls of the scoops are concave in shape and have welded handles attached. The industrial scoops are used in agriculture, horticulture and food processing applications to move materials such as dry fertilizer, grain, rice or other food products. The pharma scoops are primarily used in the pharmaceutical industry to transfer powders, liquids or pills from one location to another. Both scoops will be imported in various lengths and sizes that can hold quantities ranging from 8 ounces to 160 ounces. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N351212: 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: A child-size costume identified as Boho Pirate, which consists of a short-sleeved dress, head tie, hat, waist sash, and belt with skull, and features a neck with raw, unfinished edges and narrow exposed elastic stitched on with a single line of long, loose straight stitching in the front. The back neck has large, visible, loose overlock stitching. The short sleeves have narrow exposed elastic stitched on with a single line of straight stitching. The sleeve ends and pointed handkerchief hem are raw and unfinished. The flimsy half elastic waist consists of a single strip of exposed elastic stitched directly to the back waist of the dress with one row of long, loose straight stitching. |
| Reason: The flimsy man-made knitted and woven textile pullover dress provides the essential character of the set. |
| Ruling Date: July 17, 2025 |
N351219: 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: A child-size costume identified as Patchwork Scarecrow, which consists of an overall dress with attached long-sleeved top, separate collar, rope belt, hat, and attachable flower, and features large, visible, loose overlock stitching on the neck and overall straps. The bib front is finished all around with a single ruffle with raw unfinished edges. The sleeves have narrow exposed elastic stitched on with a single line of large loose straight stitching. The sleeves also have raw cut fringe to depict hay. The narrow, exposed elastic waist is also stitched directly onto the dress with a single line of long loose straight stitching. The hem bottom is raw and unfinished. The dress is entirely constructed with long, loose, straight stitching. Although the bib front has a small patch pocket stitched on, the dress is not well-made. |
| Reason: The flimsy man-made knitted textile pullover dress provides the essential character of the set. |
| Ruling Date: July 17, 2025 |
N351264: The tariff classification of a costume from China and Vietnam
| HTS: 9505.90.6000, free + 20% + 10%, “Festive, carnival or other entertainment articles, including magic tricks, and practical joke articles; parts and accessories thereof: Other: Other.” |
| Item: A child-size costume identified as Native American Princess, which consists of a sleeveless one shoulder dress, armband and boot tops, and features raw, unfinished edges around the top opening, wearer’s left armhole and set of ties for the wearer’s right shoulder. The top back of the dress features narrow, exposed elastic stitched on with a single line of long, loose, straight stitching. There are two non-functional, decorative lace-up panels on either side of the skirt with a thin shoestring strung through the loops. The flimsy half elastic waist consists of a strip of narrow exposed elastic stitched directly to the back waist of the dress with one row of long, loose straight stitching. The fringe hem bottom is raw and unfinished. The dress is stitched together with a single line of long, loose straight stitching. |
| Reason: The flimsy man-made knitted textile pullover dress provides the essential character of the set. |
| Ruling Date: July 17, 2025 |
N351320: The tariff classification of compression sensory swing, weighted lap pad, and weighted lap animal from China
| HTS: 6307.90.9891, 9903.01.24; 9903.01.25; 9903.88.15, 7% + 20% + 10% + 7.5%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.” |
| Item: Item #1, described as a “Compression Sensory Swing,” is a full body fabric swing designed to create a calming, cocoon-like experience and is intended for children diagnosed with autism spectrum disorder (ASD), attention-deficit/hyperactivity disorder (ADHD), and other neurodevelopmental challenges. The swing is composed of a 100% nylon tricot knit, dyed, fabric. Item #2, described as a “Weighted Lap Pad,” is designed to apply pressure to a child’s legs or torso while seated to create a calming, grounding effect and is intended for children diagnosed with ASD, ADHD, and other neurodevelopmental challenges. The lap pad consists of five layers quilted together with glass beads: 100% polyester minky microfleece knit exterior layers; a 100% polyester woven scrim fabric on the second and fourth layer; and a 100% polyester nonwoven batting middle layer. Item #3, described as a “Weighted Lap Animal,” is a dog-shaped lap pad designed to apply pressure to a child’s legs or torso while seated to create a calming, grounding effect and is intended for children diagnosed with ASD, ADHD, and other neurodevelopmental challenges. The lap pad consists of a cover and a removeable pouch insert. The cover is composed of an outer layer of 100% polyester knit faux fur plush pile fabric and a bottom layer of 100% polyester knit plush fabric. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N351322: 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: A child-size costume identified as L.O.L. Surprise Diva, which consists of a pullover dress and bow headband, depicting the L.O.L. Surprise Diva doll, and features a capped neck and deep back opening closed with a single small tab of hook and loop fastener. The short sleeves and hem bottom have large, visible, loose overlock stitching. The flimsy half elastic waist consists of a strip of exposed elastic stitched directly to the back waist of the dress with one row of long, loose straight stitching. Although the dress has a well-made neck, the dress is not well-made. |
| Reason: The flimsy man-made knitted and woven man-made textile dress provides the essential character of the set. |
| Ruling Date: July 17, 2025 |