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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N350622: The country of origin of 2nd generation and 3rd generation wheel hub bearing assemblies
| Origin: Vietnam |
| Item: 2nd and 3rd Generation Wheel Hub Bearing Assemblies which are used in passenger vehicle wheel assemblies and light trucks and sport utility vehicles (SUV), respectively. The rough-cut inner rings and other components from China are sent to Vietnam to be further processed and integrated with the Vietnamese outer ring with a flange and seal rings to create the assemblies. In Vietnam, the rough-cut rings are ground, turned, demagnetized, and heat treated to required diameters and measurements, creating precise raceways. |
| Reason: The articles are not mere bearings, but rather wheel hub units, incorporating bearings. Since the inner rings from China become races with precision raceways in Vietnam and the flange is made in Vietnam, the country of origin of the assemblies is Vietnam. |
| Ruling Date: July 21, 2025 |
N350646: The tariff classification of women’s wearing apparel from Vietnam
| HTS: (style 1) 6110.30.3059, 9903.01.25, 32% + 10%, “Sweaters, pullovers, sweatshirts, waistcoats (vests) and similar articles, knitted or crocheted (con.): Of man-made fibers: Other: Other: Other: Other: Women’s or girls’: Other.” (styles 2 and 3) 6106.20.2010, 9903.01.25, 32% + 10%, “Women’s and girls’ blouses and shirts, knitted or crocheted: Of man-made fibers: Other: Women’s.” |
| Item: Style 1 is a women’s cardigan style garment constructed from two different types of fabric. The woven portion is constructed from 90% nylon and 10% spandex. The knit portion is constructed from 92% nylon and 8% spandex. The knit fabric’s outer surface measures more than nine stitches per two centimeters in the direction the stitches were formed. Style 2 is a women’s blouse constructed from 57% polyester, 35% rayon, and 8% spandex knit fabric. The fabric’s outer surface measures at least ten or more stitches per linear centimeters measured in both directions. Style 3 is a women’s blouse constructed from 80% polyester 20% spandex knit fabric. The fabric’s outer surface measures at least ten or more stitches per linear centimeters measured in both directions. |
| Reason: N/A |
| Ruling Date: July 21, 2025 |
N350710: The country of origin of an LED flashlight from Vietnam
| Origin: Vietnam |
| Item: The flashlight is approximately 4.33 inches in length and 1.26 inches in diameter. The body is of steel tube construction. The luminescence of the flashlight can be changed by the user with a twist of the bulb head, with a maximum of 300 lumens. The LED flashlight consists of a plastic cover (lens), a reflecting cap, a PCBA (Printed Circuit Board Assembly), an SMD LED (Surface Mount Device and Light Emitting Diode) sub-assembly, a lamp holder, an aluminum alloy housing containing a battery holder and a tail cover with a power switch. All components are imported into Vietnam where they will first be made into the PCBA and the SMD LED sub-assembly. Subsequently, these PCBA and the SMD LED sub-assembly will be assembled with the balance of imported components to produce the finished flashlight. |
| Reason: Although the majority of components and materials are of non-Vietnamese origin, the PCBA and the SMD LED sub-assembly (light source) are fabricated in Vietnam. They are the most important or critical components in the subject LED flashlight, which also impart the character of the LED flashlight. |
| Ruling Date: July 21, 2025 |
N350773: The classification and country of origin of a heat pump
| HTS: 8415.90.8065, 9903.01.24; 9903.01.25; 9903.88.15, 1.4% + 20% + 10% + 7.5%, “Air conditioning machines, comprising a motor-driven fan and elements for changing the temperature and humidity, including those machines in which the humidity cannot be separately regulated; parts thereof: Parts: Other: Other: Of heat pumps.” |
| Origin: China |
| Item: The heat pump is an outdoor unit, which consists of a chassis that incorporates a compressor, a condenser, a motor and fan assembly, a four-way reversing valve, an expansive valve assembly, a control panel and an accumulator. Once paired with an indoor unit, which is imported separately, the system heats and cools spaces. The final assembly of the heat pump occurs in South Korea using components sourced from China. |
| Reason: The components sourced from China, including components that contribute to the change of temperature process, are assembled to each other and the chassis in South Korea to produce a heat pump. The steps that occur during the final assembly process are not complex, as they consist of processes such as screwing, bolting and brazing, which is recognized as a welding operation used to join pipes to heat exchangers. |
| Ruling Date: July 21, 2025 |
N351063: Country of origin determination for a 7-piece comforter set; 19 CFR 102.21(c)(2); tariff shift
| Origin: Vietnam |
| Item: A 7-piece comforter set, consisting of one comforter, two shams, one fitted sheet, one flat sheet, and two pillowcases. Each item is made from 100% polyester woven fabric. The manufacturing operations for the comforter set are as follows: In Vietnam, the face and back fabrics for the comforter and shams are woven. The fabrics for the fitted sheet, flat sheet, and pillowcases are woven. The face fabric of the comforter and shams is bleached, printed and napped. The fabric forming the sheets and pillowcases and the back of the comforter and shams is dyed and napped. The fabrics are exported to China on rolls. In China, the polyester fiberfill is manufactured. The fabric is cut and sewn to form the comforter shell, shams, sheets and pillowcases. The comforter is filled with 100% polyester fiberfill and sewn closed. |
| Reason: As the fabric comprising the subject comforters and shams is formed in Vietnam, country of origin is conferred in Vietnam. |
| Ruling Date: July 21, 2025 |
N351097: The country of origin of a door switch assembly
| Origin: Thailand |
| Item: A door switch for use with a laundry dryer, which is composed of an internal microswitch that is connected to a spring-loaded plunger. In use, the switch is installed in the door of a dryer. The manufacturing process occurs in Thailand with components primarily of Thai origin. The microswitch, which originates in Thailand, is placed within a plastic housing. Next, the plunger, spring, and lever are assembled onto the switch and covered with a plastic enclosure. Per the information provided, the spring is of Chinese origin while the remainder of the components originate in Thailand. |
| Reason: The incorporated microswitch imparts the character of the finished device. Further, the only component that originates from outside of Thailand, the spring, is clearly substantially transformed through its incorporation into the finished device. |
| Ruling Date: July 21, 2025 |
N351191: The tariff classification of a liquid micronutrient preparation from Spain
| 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: Other.” |
| Item: A liquid micronutrient preparation, which is composed of boron, pH stabilizer, and other substances. The product is designed to be applied via root and foliar feeding and functions to prevent and correct boron deficiency symptoms in crops. |
| Reason: N/A |
| Ruling Date: July 21, 2025 |
N351195: The tariff classification of Balanced Detectors from Germany
| HTS: 9027.50.4060, 9903.01.25, free + 10%, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Other.” |
| Item: Balanced Detectors, which are high-quantum efficiency (HQE) balanced photodetectors designed for operation at a wavelength of 1550 nanometers (nm) and 1064 nm respectively. Balanced Detectors are devices that utilize two precisely matched photodiodes and a differential amplifier to subtract two optical input signals from each other. The Balanced Detector consists of a laser beam detector housed in a casing (dimensions: 81.7 mm x 136 mm x 29 mm), a connector for an external electronic demodulation signal, and a base adjusted for a laser beam height of 50 mm for mounting on an optical bench. |
| Reason: N/A |
| Ruling Date: July 21, 2025 |
N351230: Country of origin determination for a 3-piece comforter set; 19 CFR 102.21(c)(2); tariff shift
| Origin: Vietnam |
| Item: A 3-piece comforter set, consisting of one comforter and two shams composed of 100% polyester woven fabric. The manufacturing operations for the comforter set are as follows: In Vietnam, the face and back fabrics for the comforter and shams are woven. Woven fabric is dyed or printed. The fabrics are exported to China. In China, the polyester staple fiberfill is manufactured. The fabric is cut and assembled by sewing into a comforter shell and pillow shams. The comforter is filled with polyester fiberfill, tacked, and sewn closed. |
| Reason: As the fabric comprising the subject comforters and shams is formed by the fabric-making process in a single country, that is, Vietnam, as per the terms of the tariff shift requirement, country of origin is conferred in Vietnam. |
| Ruling Date: July 21, 2025 |
N351245: The tariff classification of muzzle brakes from Sweden
| HTS: 9305.20.8060, 9903.01.25, free + 10%, “Parts and accessories of articles of headings 9301 to 9304: Of shotguns or rifles of heading 9303: Other: Other: Of rifles.” |
| Item: Precision-engineered stainless steel muzzle brakes for use on civilian bolt-action and semi-automatic sporting rifles. During use, the muzzle brakes attach to threaded rifle muzzles and redirect gas flow to reduce recoil, limit muzzle rise, maintain shooter visibility, and improve shot timing. The muzzle brakes are not for military, law enforcement, or automatic weapon use. |
| Reason: N/A |
| Ruling Date: July 21, 2025 |