Trade Law Daily is a service of Warren Communications News.

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:

Sign up for a free preview to unlock the rest of this article

Timely, relevant coverage of court proceedings and agency rulings involving tariffs, classification, valuation, origin and antidumping and countervailing duties. Each day, Trade Law Daily subscribers receive a daily headline email, in-depth PDF edition and access to all relevant documents via our trade law source document library and website.

N351208: The tariff classification of a pillow cover from China

HTS: 6304.92.0000, 9903.01.24; 9903.01.25; 9903.88.15, 6.3% + 20% + 10% + 7.5%, “Other furnishing articles, excluding those of heading 9404: Other: Not knitted or crocheted, of cotton.”
Item: The subject item, “MusNPC-WatercolorFloral-PK-GY-PRT,” is a decorative pillow cover for a nursing pillow made of 100 percent cotton muslin, printed, fabric. The cover features a 22-inch-long hidden zipper closure centered on the outer edge. The kidney-shaped pillow cover measures approximately 17 ¼ x 25 ¼ inches and has a consistent width of 8 ½ inches throughout. The pillow insert is not included.
Reason: N/A
Ruling Date: July 18, 2025

N351231: The country of origin of a sidewalk ice scraper

Origin: Vietnam
Item: The item under consideration is a sidewalk ice scraper. It is a hand tool with a long handle and a flat sharp blade, which is used to remove ice and compacted snow from sidewalks, driveways, and other paved surfaces. The manufacturing process begins in Vietnam, where Chinese-origin hot-rolled steel is laser-cut into the ice scraper blade. Also in Vietnam, 12" long round steel is punched, bent and welded onto the blade in order to form a connection point with the handle socket. The fully formed ice scraper head is then sent to China, where it is polished and powder coated. A handle socket is connected and secured, along with a wooden handle. Finally, middle and end plastic grips are attached to the handle.
Reason: The raw steel is substantially transformed in Vietnam into a fully formed ice scraper head. It is this head that contributes to the main functionality of the tool. Based upon the finishing operations performed in China, the ice scraper head is not substantially changed so as to transform it into a new article with a different name, character, or use.
Ruling Date: July 18, 2025

N351272: 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 Emerald City Witch, which consists of a short-sleeved pullover dress, hat, and hat sash, and features narrow exposed elastic stitched on the front neck with a single line of long, loose straight stitching. The back neck, short sleeves, and hem bottom are finished with large, visible, loose overlock stitching. The flimsy half elastic waist consists of a strip of narrow exposed elastic stitched directly to the back waist of the dress with a single line of long, loose straight stitching. The attached overskirt has raw unfinished edges. Although the dress has some well-made style features like gathering and two layers, the dress is not well-made. The dress is stitched together with long, loose straight stitches.
Reason: The flimsy man-made knitted textile dress provides the essential character of the set.
Ruling Date: July 18, 2025

N351277: 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: An adult-size costume identified as Full Moon Fury, which consists of a long-sleeved shirt with faux fur, shoulder padding and a mask, and features large, visible loose overlock stitching at the neck. The single ply “lapels” bordering the faux fur chest insert, have raw, unfinished edges. The top sleeves have raw, jagged cut edges and the lower faux fur sleeves have raw, unfinished edges. The bottom hem also has raw jagged cut edges, giving a tattered appearance to the werewolf’s shirt. The shirt is stitched with a single line of long, loose straight stitching.
Reason: The flimsy man-made knitted textile shirt with faux fur provides the essential character of the set.
Ruling Date: July 18, 2025

N350225: The country of origin of a digital blood pressure monitor

Origin: Cambodia
Item: The product under consideration is an Arm-type Fully Automatic Blood Pressure Monitor which consists of a motherboard (chip-on-board/COB), an air pump, a pressure sensor (pressure transducer), two valves, an LCD display, a cuff (composed of an arm cuff, an air tube, and an air plug), a lower cover, an upper cover, and other components. In Cambodia, the main PCB, MCU, resistors, capacitors, transistors, crystal oscillators, and other electronic components are soldered to form a motherboard using surface mount technology (“SMT”). Chinese-origin software source code is compiled by the Cambodian engineer to generate the firmware file based on the different functions of the order. The remaining assembly processes involve: the horn wire welding, batter reeds and buzzers (or horn assembly) assembly, pneumatic components (cuff plug, pump, solenoid valve, silicone tube) assembly, lower cover pneumatic components assembly, power socket wire (DC outlet PCB, electric outlet, and wire) soldering, back soldering, COB lower cover assembly, upper cover assembly, upper and lower cover assembly, lower cover screw, transparent sheet assembly, final inspection, and battery cover assembly. The complete device and the cuff are packaged together.
Reason: The assembly of the motherboard and programming operations performed in Cambodia substantially transform the Chinese main PCB, MCU, and other components into a product of Cambodia. The Cambodian-origin motherboard and cuff play important roles of the blood pressure monitor. Additionally, the blood pressure monitor is completed in Cambodia through sub-assembly and final assembly.
Ruling Date: July 17, 2025

N350310: The country of origin of a freeze-on-demand food mixer

Origin: China
Item: The freeze-on-demand food mixer, also referred to as the ColdSnap System, is a smart, connected, food-processing, mixer-freeze appliance with complex real-time control and remote monitoring, that can be used to create single-serve frozen desserts (ice cream, smoothies, lattes, protein shakes, cocktails, etc.) using proprietary pods. The ColdSnap System integrates a refrigeration system, motor assemblies, user interface, and a variety of printed circuit board assemblies (PCBAs), including a main control board. In the proposed manufacturing process: ColdSnap, Corp. will import the PCBAs into the United States, from China or from another third country. These PCBAs have no embedded functionality without the software, programming, configuration, and testing required to actually control and operate the ColdSnap System. Once the PCBAs are imported, proprietary software developed by ColdSnap, Corp.’s U.S.-based engineering team will be permanently loaded onto the PCBAs. After programming, the cellular connection on the PCBAs will be provisioned. Provisioning in this context refers to registration of the cellular module with ColdSnap, Corp.’s contracted cloud services provider and cloud management account. At this point, the embedded software enables all core ColdSnap System functions, including user interface, pod recognition, refrigeration cycle control, telemetry communication, and over-the-air software updates. Following testing, the programmed, active, and functional PCBAs will then be sent to China. You further note that the PCBAs are manufactured in China (or in a third country), while the board layout, engineering designs, and board logic are entirely developed in the United States.
Reason: The PCBAs manufactured in China do not undergo a substantial transformation as a result of the software loading, provisioning onto the PCBA, testing and other operations in the United States. The PCBAs retain their identity after this processing. They also have a pre-determined end use as PCBAs before such processing. These Chinese-origin PCBAs are then shipped back to China for final assembly with the other subassemblies to complete the finished product. Moreover, nearly all or the overwhelming majority of the components and subassemblies, including the PCBAs, are manufactured in China. Any non Chinese-origin components used in the manufacture of the ColdSnap System lose their identity and are substantially transformed when they are combined with the other Chinese components and Chinese subassemblies in China through a series of complex operations.
Ruling Date: July 17, 2025

N350403: The tariff classification of Nebivolol Hydrochloride (HCL) Tablets in dosage form, from India

HTS: 3004.90.9221, 9903.01.32, free, “Medicaments… consisting of mixed or unmixed products for therapeutic or prophylactic uses, put up in measured doses … or in forms or packings for retail sale: Other: Other: Other: Cardiovascular medicaments: Other.”
Item: Nebivolol HCL Tablets, imported in 2.5 mg, 5 mg, 10 mg, and 20 mg tablets, is a beta-blocker medication. It is used to treat high blood pressure (hypertension) and heart failure.
Reason: N/A
Ruling Date: July 17, 2025

N350406: The tariff classification of Dabigatran Etexilate Capsules, imported in dosage form, from India

HTS: 3004.90.9221, 9903.01.32, free, “Medicaments… consisting of mixed or unmixed products for therapeutic or prophylactic uses, put up in measured doses … or in forms or packings for retail sale: Other: Other: Other: Cardiovascular medicaments: Other.”
Item: Dabigatran Etexilate, imported in 150 mg capsules, is an oral anticoagulant in a class of medications called direct thrombin inhibitors. It is used to prevent blood clots and stroke associated with surgical procedures or conditions in the heart, such as abnormal heart rhythms.
Reason: N/A
Ruling Date: July 17, 2025

N350424: The tariff classification of a protein supplement from South Korea

HTS: 2106.90.9972, 9903.01.25, 6.4% + 10%, “Food preparations not elsewhere specified or included… Other… Other… Other… Preparations for the manufacture of beverages…Containing sugar derived from sugar cane and/or sugar beets.”
Item: The subject merchandise, “Into Jeju Spirulina Gruel,” is described as a powdered protein supplement that can serve as a meal replacement or nutritious snack. Into Jeju Spirulina Gruel comprises black bean, black barley, oats, separated soybeans, organic sugar (4%), spirulina, seaweed and kelp. Into Jeju Spirulina Gruel product is designed and intended to be consumed after being mixed with a liquid such as milk, soy milk, or water. When combined with these liquids, the powder dissolves easily, creating a smooth drinkable mixture. The powdered form of the product is stated to make it better suited for drinking rather than chewing, and it is marketed as a convenient health drink that incorporates cereal-based nutrition. The product is prepared by commencing with the careful selection of raw powdered ingredients such as barley and oats. These selected raw materials are then weighed according to the formulation requirements. Subsequently, food-grade additives are introduced into the mix, and the entire mixture is thoroughly stirred to ensure even distribution of all components. Once mixed, the product is filled into designated packaging units and sealed under hygienic conditions.
Reason: N/A
Ruling Date: July 17, 2025

N350470: The country of origin of a microwave hood combination

Origin: Mexico
Item: The microwave hood combination is an electric kitchen appliance that combines the functions of a microwave oven and a range hood (also known as a vent hood) into a single unit. It is typically installed above the cooktop and combines the convenience of microwave cooking with the ventilation necessary for removing smoke, steam, and odors from the cooking process. The microwave hood combination consists of the following key assemblies or components: a bottom plate assembly, printed circuit board assembly (PCBA), high voltage (HV) transformer, magnetron, control panel assembly, door assembly, cavity, and an outer wrapper assembly. The significant steps for producing the microwave hood take place in Mexico.
Reason: The foreign components and materials are imported into Mexico where they are manufactured into different subassemblies, and then ultimately assembled into the microwave hood combination. Further, a number of the key assemblies and components are made in Mexico. The manufacturing process, including the SMT process, is complex and meaningful. The manufacturing process in Mexico does create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into Mexico. Therefore, the country of origin of the microwave hood combination is Mexico.
Ruling Date: July 17, 2025