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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N350625: The tariff classification of a produce freshness retainer from Poland
| HTS: 3824.99.9397, 9903.01.32, 5%, “Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Other: Other: Other.” |
| Item: An “active packaging technology” that is used to inhibit ethylene in order to extend the shelf life of packaged cut produce. It consists of a mixture of several different chemicals that is applied to the outside surface of a food grade paper or polypropylene sticker. The stickers would be placed on the inside lids of clamshell packaging or inside plastic bags. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N350660: 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: A plastic decorative molding installed on the interior front door trim of an automobile, specifically around the interior door handle area on either the driver or passenger side. Its primary function is to fill and visually cover gaps between the door handle and adjacent trim parts. It does not serve any mechanical, structural, or functional role and is intended to enhance the interior finish of the vehicle. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N350661: 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: A plastic exterior trim part designed to be installed on the upper section of the front left fender of a vehicle. Its primary function is to act as a cover that conceals minor gaps or steps between body panels. It does not contribute to the vehicle’s structural integrity, safety, or mechanical operation and is merely intended to enhance the exterior finish of the vehicle. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N350662: 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: A plastic exterior garnish component attached to the lower outer side of the left and right rear doors of an automobile. It is installed in a visibly exposed location and covers the lower portion of the rear doors. It does not impact the driving performance, structural strength, crash resistance, or mechanical function, and is intended to enhance the exterior finish of the vehicle. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N350663: 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: A plastic exterior garnish component attached to the lower outer area of the front left fender of an automobile. The product is designed to visually unify the connection between the fender and the side skirt, while concealing any gaps or step differences between the adjoining panels. It does not impact the vehicle performance, structural safety, or mechanical operation, and is intended to serve as a cover to enhance the exterior finish of the vehicle. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N350777: The tariff classification of an eye mask 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: An “eye mask” which is intended to be worn over the eyes to block out light. The eye mask is composed of three layers: a 100% polyester knitted pile faux fur, dyed brown, fabric front layer; a 100% polyester batting middle layer; and a 100% polyester woven satin, dyed brown, fabric back layer. The mask, measuring 8 inches in length by 4 inches in width, features two antlers composed of 100% polyester knit dyed brown fabric, two embroidered black eyes, and a red pom-pom nose glued to the front layer. The mask also features an elasticized band sheathed in a 100% polyester woven, dyed brown, fabric sewn at each end to allow the mask to be worn around the head. |
| Reason: N/A |
| Ruling Date: July 17, 2025 |
N350814: The country of origin of a bill validator
| Origin: China and UK |
| Item: A banknote authentication device used to verify the authenticity of paper currency and detect security features embedded in genuine banknotes. There are three separate manufacturing scenarios. In scenario one, the imported bill validators are assembled in China from components of Chinese origin. The proprietary software is then downloaded in the UK and the bill validators are tested before being shipped to the United States. The software in this scenario is developed in the UK. In scenario two, all assembly continues to be done in China, however, the standard firmware and datasets are also applied in China to allow testing of the units with dummy bank notes. This firmware is then removed prior to shipping to the UK, therefore the finished unit is shipped to the UK with no firmware. In the UK, the relevant firmware and dataset is applied along with final testing and configuration before shipping. In scenario three, the main PCBA is manufactured in the UK instead of China and final assembly is completed in the UK in addition to the firmware and dataset being added. |
| Reason: The assembly of the bill validator in China, in scenarios one and two, provides the essence of the finished bill validator. The item can only be used as a bill validator when it leaves China, and the addition of the proprietary software only enhances the usability. The addition of the software, calibration and testing performed in the UK does not substantially transform the article into a new and different article with a name, character, and use different than when it leaves China. For scenario three, the creation of the PCBA in the UK using surface mount technology along with the addition of the firmware, transforms the individual Chinese components into a bill validator with a new name, character, and use, different from that possessed by the article prior to the processing. The assembly process performed in China then enhances the use of the PCBA but does not substantially change the ability to verify the authenticity of paper currency. |
| Ruling Date: July 17, 2025 |
N350835: The tariff classification of blood glucose test strips from South Korea
| HTS: 3822.19.0080, 9817.00.96, free, “[d]iagnostic or laboratory reagents on a backing, prepared diagnostic or laboratory reagents whether or not on a backing, whether or not put up in the form of kits, other than those of heading 3006; certified reference materials: [d]iagnostic or laboratory reagents on a backing, prepared diagnostic or laboratory reagents whether or not on a backing, whether or not put up in the form of kits: [o]ther: [o]ther: [o]ther.” |
| Item: The items in consideration are Meijer Essential Blood Glucose Test Strip, and Bigfoot Blood Glucose Test Strip, which are made of different layers and one layer contains a chemical mixture (a reagent). They are designed solely for use by persons with diabetes to monitor their blood glucose levels. The blood glucose test strip is designed to be inserted into a blood glucose meter. The user applies a small sample of blood obtained using a lancing device to the test strip. Glucose in the blood sample reacts with the chemical mixture on the test strip. This yields a small electrical current. The blood glucose meter measures this current. It then shows the blood glucose result proportional to the current. The chemical mixtures do not contain antigens or antisera. |
| Reason: The blood glucose test strips are specially designed for the use or benefit of people with diabetes, enabling them to monitor their blood sugar levels regularly when used with the blood glucose meters. Based on the precedents, they qualify for duty-free treatment under subheading 9817.00.96, HTSUS. |
| Ruling Date: July 17, 2025 |
N350883: The country of origin of LED light bars
| Origin: Thailand |
| Item: Three models of LED lights identified as the Rechargeable Motion Sensing Light Bars. All components are of Chinese-origin, except for the LEDs, mainboard set screws, end cap set screws, and cable, which are made in Thailand. The Chinese-origin components and materials are shipped to Thailand where they are combined with the Thai-made components to fabricate the finished LED lights. The assembly process in Thailand begins with the production of the PCBAs, in which, the Chinese-origin PCBs are populated with the Thai-origin LEDs via the SMT (Surface Mount Technology) process to produce the light source. The assembly operations following the SMT include 17 steps to assemble the components into a finished light involving screwing, soldiering, taping, inspection and testing. |
| Reason: Although the overwhelming majority of components and materials are imported (of non-Thai origin), the PBCAs (light source) are fabricated in Thailand. They are the most important or critical components in the subject LED light bars, which also impart the character of the LED light bars. The SMT process to create the light source along with other assembly operations performed in Thailand are complex and meaningful, thus, the substantial transformation has occurred. As such, the country of origin of the LED light bars is Thailand for purposes of current trade remedies. |
| Ruling Date: July 17, 2025 |
N350928: The tariff classification of footwear insoles from China
| HTS: 6406.90.9000, 9903.01.24, 9903.01.25, free + 20% + 10%, “Removable insoles, heel cushions and similar articles…Other…Other.” |
| Item: The items under consideration are thin, firm (and firm/flexible) footwear insoles/inserts which are made from layered woven carbon fibers that have been impregnated with epoxy/resin and fused and cured using heat and rolling. The inserts are then cut, polished, and packed in varying sizes and shapes. |
| Reason: As the foot plates are not designed to cure any physical abnormalities or conditions, the Thrive Orthopedics carbon fiber foot plate inserts do not satisfy the five factors set out by CBP. They are not distinguishable by design or form from articles useful to non-handicapped people. They are not imported with any extraordinary construction features that signal they are for use by handicapped people, imported designed for use by a specific person. They are not “specifically designed or adapted” for the handicapped. They do not have design features that would discourage use by the general population. Instead, they are imported in multiple sizes and offered for sale in retail shops and on the internet. In this regard, when compared to inserts sold at retail to the general population, they do not have any design features that distinguish them from ordinary footwear used by the general public. Therefore, a secondary classification in subheading 9817.00.96 will not apply. |
| Ruling Date: July 17, 2025 |