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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N351106: The country of origin of a CEFALY Connected kit
| Origin: Taiwan |
| Item: The CEFALY Connected kit is intended for both the acute treatment and preventive therapy of migraines in adults. The imported set includes one main device (CEFALY Connected), a charging dock, a kit of three reusable adhesive electrodes, a resealable electrode bag, USB charging cable, a plastic carrying case, user manuals, quick start guide, and packaging. The printed circuit board assemblies (PCBAs) of the main device are manufactured and programmed with firmware in Taiwan. |
| Reason: The functionality of the CEFALY Connected (main device) is driven by its main PCBA and flex PCBA, which are manufactured in Taiwan. The assembly of the PCBAs and programming operations performed in Taiwan substantially transform the individual components into a product of Taiwan. |
| Ruling Date: July 31, 2025 |
N351234: The country of origin of Hydraulic Cylinders for mechanical equipment
| Origin: Korea |
| Item: The manufacturing and processing of products exported to the U.S. is performed in Korea. The manufacturing process of a hydraulic cylinder can be broadly divided into four main steps: 1. Rod Part manufacturing 2. Rod All Group assembly 3. Tube Part manufacturing and 4. Connection of the Rod All Group with the Tube Part Through this process, the finished hydraulic cylinder attains its designed purpose, characteristics, and functionality. |
| Reason: The processes that take place in South Korea substantially transform the individual parts and components sourced from China, EU, and Japan to complete the Hydraulic Cylinders. |
| Ruling Date: July 31, 2025 |
N351259: The classification of a direct mail package with a tote bag from China
| HTS: (printed letter and donation solicitation literature) 4901.10.0040, 9903.01.22, 9903.01.31, 9903.88.15, free + 7.5%, “Printed books, brochures, leaflets and similar printed matter, whether or not in single sheets: In single sheets, whether or not folded: Other.” (return envelope) 4817.10.0000, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Envelopes, letter cards, plain postcards and correspondence cards, of paper or paperboard; boxes, pouches, wallets and writing compendiums, of paper or paperboard, containing an assortment of paper stationery: Envelopes.” (tote bag) 4202.92.4500, 9903.01.24, 9903.01.25, 9903.88.03, 20% + 20% + 10% + 25%, “travel, sports, and similar bags, with outer surface of sheeting of plastic, other.” |
| Item: The mailer contains printed, single sheets of information including a letter, solicitation literature, and a postage-paid return envelope. The purpose of the mailer is to solicit donations for Doctors Without Borders. These printed items are packaged with a tote bag printed with the words “Doctors Without Borders Supporter.” |
| Reason: N/A |
| Ruling Date: July 31, 2025 |
N351263: The country of origin of a battery cell
| Origin: China |
| Item: The merchandise under consideration is identified as a lithium iron phosphate battery cell, and is described as a prismatic cell with a nominal voltage of 3.2 VDC, a nominal capacity of 314 Ah, and a nominal energy of 1004.8 Wh. The subject battery cell will be produced using an automated process and from materials and components sourced from China and the United States. The process begins in China with manufacturing semifinished battery electrodes. |
| Reason: The battery cell is formed in China before it is sent to Indonesia for activation. In China, domestic and foreign materials are processed into semi-manufactured materials and subcomponents, which are subsequently used to create the battery cell. |
| Ruling Date: July 31, 2025 |
N351308: The country of origin of brake calipers
| Origin: Mexico |
| Item: The articles under consideration have been identified as brake calipers, which have the primary function of applying pressure to the brake pads, which in turn creates friction against the brake rotor or disc. The brake calipers are assembled in Mexico using brake caliper cores and brake pads from various countries. |
| Reason: The production of the brake calipers in Mexico involved combining multiple components of different origins to make a new product. Accordingly, the country of origin of the brake calipers for marking purposes is Mexico, the last country in which the brake calipers underwent production. |
| Ruling Date: July 31, 2025 |
N351400: The tariff classification of a weighted vest from China
| HTS: 6113.00.9086, 9903.01.24; 9903.01.25; 9903.88.15, 7% + 20% + 10% + 7.5%, “Garments, made up of knitted or crocheted fabrics of heading 5903, 5906, or 5907: Other: Other: Other: Women’s or girls.” |
| Item: The Harkla’s Weighted Compression Vest is composed of an outer and inner 100% polyester flat knit fabric bonded together with a rubber application in between. The rubber application is visible to the naked eye. The vest features a round neckline, oversized armed openings secured with hook-and-loop fasteners at the side and on the shoulders, interior pockets at the bottom front and back that can hold removable weights, side slits and a hemmed bottom. |
| Reason: The polyester vest is the component and not the pellets in the vest that imparts the essential character of the garment. |
| Ruling Date: July 31, 2025 |
N351419: The tariff classification of metal furniture from Vietnam
| HTS: 9403.10.0040, 9903.85.08; 9903.01.25, free + 50% + 10%, “Other furniture and parts thereof: Metal furniture of a kind used in offices, Other.” |
| Item: The “Mini-Max Equipment Front End Module (EFEM)” is an unassembled and unequipped metal semiconductor cabinet frame. The powder coated metal frame is constructed of 65% cold rolled steel, 30% aluminum (6061-T6), 3% plastic (acrylic, polycarbonate), and 2% stainless steel. The cabinet frame will contain panels, partitions, frame rails, doors, protector plates, washers, hinges, stops and screws. |
| Reason: N/A |
| Ruling Date: July 31, 2025 |
N351463: The tariff classification of rollators from China
| HTS: 9021.10.0090, 9817.00.96, free, “[o]rthopedic appliances, including crutches, surgical belts and trusses; splints and other fracture appliances; artificial parts of the body; hearing aids and other appliances which are worn or carried, or implanted in the body, to compensate for a defect or disability; parts and accessories thereof: [o]rthopedic or fracture appliances, and parts and accessories thereof: [o]ther” |
| Item: Five styles of rollator with aluminum frames. |
| Reason: N/A |
| Ruling Date: July 31, 2025 |
N351488: The tariff classification of energy bars from Turkey
| HTS: (if imported in airtight containers) 2005.99.1000, 9903.01.25, 6.4% + 10%, “other vegetables prepared or preserved otherwise than by vinegar or acetic acid, not frozen…other vegetables and mixtures of vegetables…carrots in airtight containers.” (If the containers are not airtight) 2005.99.9700, 9903.01.25, 11.2% + 10%, “other vegetables prepared or preserved otherwise than by vinegar or acetic acid, not frozen…other vegetables and mixtures of vegetables…other.” |
| Item: The subject merchandise, “PepCubes - Walnut Version,” “PepCubes - Vegan Version,” and “PepCubes - Orange Version,” are described as energy bars with no added sugar or artificial sweeteners. The products are marketed toward health-conscious consumers and will be sold to health food stores, specialty grocers, and online wellness retailers. |
| Reason: N/A |
| Ruling Date: July 31, 2025 |
N351489: The tariff classification of catalytic converters from various countries
| HTS: 8421.32.0000, 9903.94.05; 9903.01.33, free + 25%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for gases: Catalytic converters or particulate filters, whether or not combined, for purifying or filtering exhaust gases from internal combustion engines.” |
| Item: The items under consideration are described as used catalytic converters, which are devices in a vehicle’s exhaust system that reduce harmful emissions from being released into the atmosphere. The catalytic converters being imported are used and are said to be imported to extract the platinum, palladium, rhodium, and rare earth elements through a process that includes mechanical de-canning, chemical assays, metallurgical separation, and refining. |
| Reason: N/A |
| Ruling Date: July 31, 2025 |