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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N351720: The tariff classification of lockout hasps from China
| HTS: 7326.90.8688, 9903.01.24; 9903.81.90; 9903.01.25; 9903.88.03, 2.9% + 20% + 50% + 10% + 25%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The items under consideration are described as lockout hasps which are used to secure machinery power switches and for other applications. The lockout hasps are composed of two high tensile steel plates which pivot around a central connection point. |
| Reason: N/A |
| Ruling Date: Aug. 7, 2025 |
N351767: The country of origin of ratchet tie downs
| Origin: Vietnam |
| Item: The products in question are 1 in. x 12 ft. Reflective Ratchet Tie Downs, imported fully assembled in a retail package of 4 ratchet tie downs. The ratchet tie downs will be produced in two countries, China and Vietnam. In Vietnam, the webbing is then flattened and stretched using a high-temperature calendaring/stretching machine. Reflective strips are then heat-transferred onto the center of the webbing using a heat transfer machine. |
| Reason: The straps are produced in Vietnam from Chinese polyester yarn and maintain their name, character, and use as tie down straps after simple assembly in Vietnam with the Chinese origin ratchet components. |
| Ruling Date: Aug. 7, 2025 |
N351807: The country of origin of automotive air filters
| Origin: China |
| Item: The items under consideration are described as automotive air filters, which are a component of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The automotive air conditioning filters are assembled in Thailand using components from Thailand and China. |
| Reason: The manufacturing and assembly process performed in Thailand is not considered complex. The Chinese filter media is the primary filtering component of the finished filters. While the media is pleated in Thailand and a few other minor components are added, the media does not become a new article. |
| Ruling Date: Aug. 7, 2025 |
N351809: The country of origin of cabin air filters
| Origin: China |
| Item: The items under consideration are described as cabin air filters, which are a component of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The cabin air filters are assembled in Thailand using components from Thailand and China. |
| Reason: The manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the Chinese filter media is the primary filtering component of the finished filters. While the media is pleated in Thailand and a few other minor components are added, the media does not become a new article |
| Ruling Date: Aug. 7, 2025 |
N351110: Classification, country of origin and marking determination for a children’s hooded bath towel
| HTS: 6302.60.0020, 9903.01.25, 9.1% + 10%, “Toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton: Towels: Other.” |
| Origin: El Salvador |
| Item: The subject merchandise, identified as “Everykid Towel (EKT),” is a children’s hooded bath towel made of a 100% cotton woven terry toweling fabric with a dobby border. The terry toweling fabric is formed in India and then imported into the U.S. The towels are exported for further processing to El Salvador. |
| Reason: The country of origin is conferred by the last country in which an important assembly or manufacturing process occurred, that is, El Salvador. |
| Ruling Date: Aug. 6, 2025 |
N351330: The country of origin of quartz surface products
| Origin: Thailand |
| Item: The merchandise under consideration is quartz surface products. The natural quartz is mined in either China or India. The quartz is crushed, purified, and then further ground to produce quartz powder and quartz sand. The quartz powder and quartz sand are then shipped to Thailand. In Thailand, the quartz and quartz powder are combined with resin, coloring, a coupling agent, a curing agent, and titanium dioxide. |
| Reason: The crushed quartz, quartz sand, and resin from China or India lose their individual identities and are substantially transformed in Thailand. |
| Ruling Date: Aug. 6, 2025 |
N351452: The tariff classification of an intake manifold with a throttle body for an automobile from Mexico
| HTS: 8419.90.3000, 9903.01.27, 9903.01.01, free + 25%, “Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment for heading 8514), for the treatment of materials by a process involving a change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Parts: Of heat exchange units.” |
| Item: The item under consideration has been identified as an automotive intake manifold with throttle body, which is made of plastic polymer. The article is made for gasoline powered internal combustion engines. The manifold distributes a mixture of air and fuel to the intake ports of the engine. |
| Reason: N/A |
| Ruling Date: Aug. 6, 2025 |
N351457: The tariff classification of a module imported from Canada
| HTS: 8414.59.6595, 9903.01.10, 9903.01.26, 2.3% + 35%, “Air or vacuum pumps, air or other gas compressors and fans; ventilating or recycling hoods incorporating a fan, whether or not fitted with filters; gas-tight biological safety cabinets, whether or not fitted with filters; parts thereof: Fans: Other: Other: Other: Other: Other.” |
| Item: The Blower subassembly, which will be installed in the 331 B Module, consists of a Divert and Slop Blower and a motor. The rotary blower is designed to increase the pressure of the low-pressure gas stream that is received from adjacent tanks. The discharge pressure from the blower is 5.13 pounds per square inch gauge, and the output of the motor is 29.8 kilowatts. |
| Reason: N/A |
| Ruling Date: Aug. 6, 2025 |
N351459: The tariff classification of a pump subassembly from Canada
| HTS: 8413.70.2022, 9903.01.26, 9903.01.10, free + 35%, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Other centrifugal pumps: Other: Other: Single-stage, single-suction, frame-mounted: With discharge outlet under 7.6 cm in diameter.” |
| Item: The Pump Subassembly consists of a Divert Water Pump and a Slop Water Pump. The Divert Water Pump and Slop Water Pumps receive separate streams of processed water from separate tanks in a tank farm installed at the Nanushuk Processing Facility in Alaska. The pumps are single stage, single suction pumps that each feature a discharge outlet that measures 2.38 inches in diameter. |
| Reason: N/A |
| Ruling Date: Aug. 6, 2025 |
N351592: The tariff classification of a bottle pouch, a bottle bumper, and a straw topper from Cambodia
| HTS: (Straw Topper) 3926.40.0090, 9903.01.25, 5.3% + 10%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Statuettes and other ornamental articles: Other.” (Bumper) 3926.90.9989, 9903.01.25, 5.3% + 10%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” (Pouch) 4202.92.9700, 9903.01.25, 17.6% + 10%, “other containers and cases, with outer surface of plastic sheeting material, other, other, other, other.” |
| Item: The “Hydration Accessories Set” is composed of a bottle pouch, a silicone bumper, and a PVC straw topper. The three articles are not considered a set for tariff purposes since each article performs a different function in relation to the bottle; they do not function together toward the same activity. As such, they will be classified separately under their appropriate subheadings. The pouch is constructed with an outer surface of plastic sheeting. It has a zipper closure and two straps that allow it to be wrapped around a water bottle. |
| Reason: N/A |
| Ruling Date: Aug. 6, 2025 |