Recent CBP NY Rulings

October 22, 2025 |Customs 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.

Start My Free Preview

N351152: The tariff classification of motocross boots from Italy

HTS: 6402.91.9065, 9903.01.25, 20% + 10%, “Other footwear with outer soles and uppers of rubber or plastics: Other footwear: Covering the ankle: Other: Other: Other: Valued over $12/pair: Other: For women: Other.”

Item: Two styles of over-the-ankle, below-the-knee, high-performance motocross boots, the uppers of which have external surface areas consisting of 70% polyurethane (PU) rubber or plastics and 30% microfiber. The external surface areas of the outer soles in contact with the ground are rubber/plastics. Item 1 has small metal shields attached at the front of the outer sole unit to protect against wear. The front of the upper appears to be stitched down to the outer sole unit. Item 2 appears to have rubber or plastics covering the juncture where the upper material and the outer sole meet. The boots are designed specifically for off-road motorcycle riding.

Reason: N/A

Ruling Date: July 22, 2025

N351184: The country of origin of boiler wall panels

Origin: China

Item: The merchandise under consideration is referred to as a boiler wall panel for a power generating boiler used in a fossil fuel utility. The panels are composed of carbon or alloy steel tubes and are used as replacement or repair components for existing boiler walls. The boiler wall panel is assembled using sub panel assemblies manufactured in China, where ten carbon or alloy steel tubes (manufactured to ASTM A210 specification) are joined with membrane bars. An automated panel welding machine that uses either a metal inert gas welding process or a submerged arc welding process welds the membrane bars and tubes to form a single uniform wall panel. The ten-tube sub panel assemblies are sent to Vietnam where two panels are welded together to create a twenty-tube assembly.

Reason: The sub panel assemblies are manufactured in China and arrive in Vietnam with a pre-determined end use as parts of a boiler wall panel. The Chinese sub panel assembly is not substantially changed by the process of welding two panels together, the addition of an overlay layer, or by bending the panels.

Ruling Date: July 22, 2025

N351185: The country of origin of boiler wall panels and superheater pendants

Origin: Vietnam

Item: The first items under consideration are referred to as boiler wall panels, which include a flat panel configuration and a bent panel configuration. They are described as replacement components for a power generating boiler used in a fossil fuel utility, and are made from carbon or alloy steel tubes, membrane bars, and an Inconel overlay. The second item under consideration is referred to as a superheater pendant, which is described as a flat assembly with vertical tubes arranged in a series of U-shaped, nested loops. The outermost tube forms the largest radius loop and curves around the outer edge of the pendant. The production of the boiler wall panels and the superheater pendants will occur in Vietnam using Chinese materials.

Reason: material lengths of tubing, cast slip spacers, and wire are sent to Vietnam where they are assembled into boiler wall panels and superheater pendants. These materials emerge from the process with a new name, character, and use, different from that possessed by the metal tubing prior to the processing.

Ruling Date: July 22, 2025

N351249: The tariff classification and country of origin of sockets, a drive bit socket and an impact socket adapter

HTS: (drive socket, impact socket and spark plug socket) 8204.12.0000, 9903.01.25, 9% + 10%, “hand-operated spanners and wrenches; socket wrenches, with or without handles, drives or extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: adjustable, and parts thereof.” (drive bit socket) 8207.90.6000, 9903.01.25, 4.3% + 10%, “interchangeable tools for hand tools, whether or not power operated, or for machine-tools, including dies for drawing or extruding metal, and rock drilling or earth boring tools; base metal parts thereof: other interchangeable tools, and parts thereof: other: other: not suitable for cutting metal, and parts thereof: for handtools, and parts thereof.” (impact socket adapter) 8466.10.0175, 9903.01.25, 3.9% + 10%, “Parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465…; tool holders for any type of tool for working in the hand: Tool holders and self-opening dieheads: Other.”

Origin: Vietnam

Item: A drive socket which is a one-piece tool that is cylindrical in shape and hollow in the center. It features a square driver hole that fits into a ratchet or socket handle. A drive bit socket which is a two-piece tool that is composed of a bit holder socket with a press-fit bit. An impact socket which is a one-piece tool that is similar to a drive socket, except it is designed to be used with pneumatic or electrical tools and has stronger impact resistance and durability. An impact socket adapter, which is a tool attachment that allows the use of sockets or bits with tools like impact drivers or drills. A spark plug socket, which is a specialized type of deep socket designed to remove and install spark plugs in an engine ignition system. For all of the tools, raw steel is sourced from China and sent to Vietnam and manufactured into the finished tools. The manufacturing process includes cold forging the steel into the overall shape of each tool and then further machining, such as chamfering, punching, grinding, polishing, etc. In the case of the impact socket adaptor, a ball-lock mechanism is installed into the tool. In the case of the drive bit socket, Chinese-origin steel is cut in Vietnam into the final form of the bit and inserted into the socket. The spark plug socket is assembled with a Chinese-origin magnetic insert in Vietnam.

Reason: The raw steel is substantially transformed in Vietnam into finished tools. All manufacturing, assembly and finishing operations occur in Vietnam. In the case of the impact socket adapter and spark plug socket, the addition of the Chinese-origin steel ball, steel spring and magnetic insert does not effect a substantial transformation on the steel tools.

Ruling Date: July 22, 2025

N351276: The country of origin of nonalloy prestressed concrete (PC) Strand

HTS: 7312.10.3012, 9903.81.97; 9903.01.33, free + 25%, “Stranded wire ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: Stranded wire, rope and cables: Stranded wire: Other: Other: For prestressing concrete: other.”

Origin: U.K.

Item: The product to be imported is nonalloy prestressed concrete (PC) Strand. The PC Strand consists of 7-wire construction and is made to EN ISO 16120-1:2017 or EN ISO 16120-4:2017 standards. This product will be imported in coils and wrapped in paper to protect the coils from corrosion during transport. Wire rod with a diameter of 11 and 13 mm is manufactured in the United Kingdom (U.K.) from steel that is melted and poured in the U.K. Next, the wire rod is shipped in coils to Sweden and first undergoes pickling to remove away the scale. Then the wire is continuously cold-drawn where the wire is reduced in 8 to 9 steps to 4.1 to 5.3 mm in diameter. Afterwards, seven wire spools are placed in a stranding machine where the wires are stranded into PC Strand

Reason: The twisting of the wire into PC Strand is not complex enough to constitute a substantial transformation.

Ruling Date: July 22, 2025

N351299: 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 Roman Beauty Toga, which consists of a one-shoulder top with attached drape, long skirt, headpiece, armbands, belt and pin-on medallion, and features exposed elastic at the back neck and a turned a stitched front. The attached drape and the hem bottom are raw and unfinished. The exposed elastic waist is stitched on with a single line of long, loose straight stitching. The pullover top is constructed with a single line of long, loose, straight stitching.

Reason: The flimsy man-made knitted textile top imparts the essential character of the set.

Ruling Date: July 22, 2025

N351312: The tariff classification of blood glucose monitoring kits from South Korea

HTS: 9027.89.4530, 9903.01.25; 9817.00.96, free, “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: Other: Other: Electrical: Chemical analysis instruments and apparatus.”

Item: Five glucose monitors which are all very similar with only a small change in shape and size, and a few additional features such as Bluetooth connectivity. The blood glucose monitors operate by using a disposable blood glucose test strip which is inserted into the blood glucose monitor. The blood glucose monitoring kits contain a standard set of components, which includes a blood glucose monitor, a carrying case, an owner’s guide, lancets, and two CR2032 batteries.

Reason: The essential character of the blood glucose monitoring kits is imparted by the blood glucose monitor. The blood glucose monitors perform a chemical analysis on a diabetic’s blood sample to determine if their levels are too high or too low, which is a direct link to the physical impairment. Accordingly, the kits are specifically designed for use by the handicapped for secondary classification purposes.

Ruling Date: July 22, 2025

N351315: The tariff classification of blood ketone monitoring kits from South Korea

Item: Two blood ketone monitoring kits whose only difference is that the BT version has Bluetooth functionality in addition to reading the measurements on the screen. Blood ketone monitors operate by using a disposable blood ketone test strip which is inserted into the blood ketone monitor. The blood ketone monitoring kits contain a standard set of components, which includes a blood ketone monitor, a carrying case, an owner’s guide, lancets, lancing devices, two CR2032 batteries, and test strips.

Reason: The essential character of the blood ketone monitoring kits is imparted by the blood ketone monitor. The blood ketone monitoring meters perform a chemical analysis on a diabetic’s blood sample to determine if their levels are too high or too low, which is a direct link to the physical impairment. Accordingly, the kits are specifically designed for use by the handicapped for secondary classification purposes.

Ruling Date: July 22, 2025

N351328: The tariff classification of a costume from China and Vietnam

Item: A child-size costume identified as L.O.L. Surprise Queen Bee, which consists of a short-sleeved pullover dress and petti-skirt, depicting the doll and character, and features narrow elastic at the neck and short sleeves with large loose overlock stitching. The front waist has a faux belt made of ribbon and 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. The flimsy hem bottom has large, visible, loose overlock stitching that is unraveling. Although the dress has some gathering in front, 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 22, 2025

N350492: The country of origin of high voltage distribution cabinets

Origin: U.S.

Item: There are three items at issue with this request, which are all described as electrical distribution cabinets used within a complex production line to distribute electricity to an assembly line station. The assembly process for the subject cabinets occurs in China with components from various countries of origin. In China, circuit breakers, which originate in Bulgaria and the U.S., are added to the cabinet along with metal components, such as DIN rails and cable ducts from various countries. Next, Chinese power supplies, an internal thermostat from Germany and an input/output module from Singapore are added. The U.S. origin PLC CPU is then installed within the cabinet. Fan units, terminal blocks, LED lights, and switches that originate from various locations including Germany, the U.S. and Mexico. Finally, a 24V power supply from the U.S. is installed prior to the cabinet being closed and prepared for shipment to the U.S.

Reason: The PLC device along with the various electrical circuit breakers impart the essence of the device. These devices extensively contribute to the electrical capabilities necessary for the intended function of the finished device. The assembly process is not significantly complex in order to substantially transform these articles into new and different articles of commerce.

Ruling Date: July 21, 2025