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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N351338: Country of origin and marking determination for an outdoor pillow and seat cushions; 19 CFR 102.21(c)(2); tariff shift
| Origin: U.S. |
| Item: The outdoor pillow and cushions, are constructed of an outer shell of 100 percent acrylic woven fabric and is stuffed with 100 percent polyester fiberfill. The acrylic fiber is woven in the U.S. and the items are assembled in China. |
| Reason: As the only fabric incorporated in the items, is formed in a single country, that is, the United States, as per the terms of the tariff shift requirement, country of origin is conferred in the United States. |
| Ruling Date: Aug. 7, 2025 |
N351354: Country of origin determination for a feather bed protector and a comforter protector; 19 CFR 102.21(c)(2); tariff shift
| Origin: Pakistan |
| Item: The subject merchandise, identified as a “Comforter Protector” and a “Featherbed Protector,” are encasement covers designed to protect a comforter or featherbed from bed bugs, dust mites and allergens. The protectors are composed of 100% cotton woven fabric which has been dyed white. The manufacturing operations for the featherbed protector and comforter protector are as follows: Pakistan: Cotton woven fabric for the face and back is formed. Fabric is shipped in rolls to China. China: Fabric is bleached and dyed. Fabric is cut and assembled by sewing into the protector. Protectors are packaged and shipped to the United States. |
| Reason: As the fabric comprising the featherbed and comforter protectors is formed in a single country, that is, Pakistan, country of origin is conferred in Pakistan. |
| Ruling Date: Aug. 7, 2025 |
N351355: Country of origin determination for a mattress or box spring protector; 19 CFR 102.21(c)(2); tariff shift
| Origin: Pakistan |
| Item: The subject article, identified as a “Mattress Box Spring Protector,” is a cover designed to fully encase and protect a mattress or box spring from bed bugs, dust mites and allergens. The protector is composed of 100% cotton woven fabric. The manufacturing operations for the mattress/box spring protector are as follows: Pakistan: Cotton woven fabric for the face and back is formed. Fabric is shipped in rolls to China. China: Fabric is bleached and dyed. Fabric is cut and assembled by sewing into the protector. Protectors are packaged and shipped to the United States. |
| Reason: As the fabric comprising the mattress box spring protector is formed in a single country, that is, Pakistan, country of origin is conferred in Pakistan. |
| Ruling Date: Aug. 7, 2025 |
N351356: Country of origin determination for waterproof featherbed protector and mattress box spring protector; 19 CFR 102.21(c)(2); tariff shift
| Origin: Pakistan |
| Item: The subject articles, identified as a “Waterproof Featherbed Protector” and “Mattress Box Spring Protector,” are covers designed to encase and protect a featherbed, mattress, and box spring from bed bugs, dust mites and allergens. The protectors are composed of 100% cotton woven fabric which has been dyed white and is laminated on the inner surface with a sheeting of compact thermoplastic polyurethane (TPU) to protect from spills, stains and allergens. The manufacturing operations for the waterproof featherbed protector and mattress/box spring protector are as follows: Pakistan: Cotton woven fabric for the face and back is formed. Fabric is shipped in rolls to China. China: Fabric is bleached and dyed. Fabric is laminated with thermoplastic polyurethane (TPU). Sewing thread and zipper are produced. Fabric is cut and assembled by sewing into the protector. |
| Reason: As the fabric comprising the featherbed protector and mattress/box spring protector, is formed in a single country, that is, Pakistan, country of origin is conferred in Pakistan. |
| Ruling Date: Aug. 7, 2025 |
N351453: Country of origin determination for a pillow protector and pillow insert; 19 CFR 102.21(c)(2); tariff shift
| Origin: Pakistan |
| Item: Item 1 is a pillow protector made of 100 percent cotton woven fabric that is dyed white. The pillow protector features a zipper closure on one end and comes in standard and gusseted versions. Item 2 is a down alternative toddler pillow insert. The pillow has an outer shell of 100 percent cotton woven fabric that is dyed white and stuffed with 100 percent polyester fiberfill. The manufacturing operations for the pillow protectors and pillow insert are as follows: Pakistan: Cotton shell fabric is woven. Fabric is exported to China for assembly. |
| Reason: As the fabric for the pillow protectors and pillow inserts are formed by the fabric-making process in a single country, that is, Pakistan, country of origin is conferred in Pakistan. |
| Ruling Date: Aug. 7, 2025 |
N351455: The country of origin of a spark module for a gas range
| Origin: China and Thailand |
| Item: The merchandise under consideration is described as a spark module for a gas range stove which is attached to a gas range oven and is responsible for generating a high-voltage spark to ignite the gas at the burners. Two configurations were provided for the manufacturing of the spark module. The first configuration has a high voltage (HV) coil, Printed Circuit Board Assembly (PCBA), cover, and epoxy potting all manufactured in China, then shipped to Thailand. The second configuration has an HV coil, cover, and epoxy potting originating in China. The PCBA is manufactured in Thailand. |
| Reason: The PCBA, which sends the electrical signal to increase the power supply to charge the capacitor and discharge to release the pulse signal to create a spark which ignites the gas, imparts the character of the finished device. The assembly process in Thailand for Configuration 1 is simple in nature and does not substantially transform the PCBA or other Chinese components into a new and different article of commerce. Country of origin for Configuration 1 is China and for Configuration 2 is Thailand. |
| Ruling Date: Aug. 7, 2025 |
N351484: The country of origin of a thin film thermal print head
| Origin: Japan |
| Item: The item under consideration is a thin film thermal print head (TPH). The TPH is used within a thermal printer, which uses heat to produce an image or text on specially coated paper, known as thermal paper. The manufacturing process for the TPH begins with a blank ceramic substrate sourced in Japan. There are two variations to the manufacturing process scenarios. In scenario A, the FPC incorporating the EEPROM is soldered to the thermal print head in China. In Scenario B, the FPC incorporating the EEPROM is soldered to the thermal print head in Japan. |
| Reason: The article produced in Japan under manufacturing Scenario A contributes to the main functionality of the finished TPH. The functional components, which include the heating elements and the electronic circuits, are already incorporated into the article when it leaves Japan. In scenario B, the additional processing in China fails to effect a substantial transformation. Adding mounting brackets to facilitate installation or adding a heatsink to dissipate heat, do not alter the main functionality of the TPH that is produced in Japan. |
| Ruling Date: Aug. 7, 2025 |
N351493: The country of origin of a walk-behind lawn mower
| Origin: Vietnam |
| Item: The product under consideration is identified as a walk-behind electric lawn mower, which incorporates an electric motor that is powered by two rechargeable 20-volt batteries. The lawn mower will be manufactured in two countries, Vietnam and China, with the following two manufacturing scenarios. Scenario one: The motor, base, cutting blade and printed circuit board assembly (PCBA) are sourced from Vietnam. The remainder of the parts of the lawn mower are procured from China. Scenario two: In this scenario all the parts are sourced from the same countries as discussed above. However, the motor, base, fan blade and blade are assembled in Vietnam. This subassembly is then sent to China where the final assembly of the lawn mower occurs as discussed in scenario one. |
| Reason: The principal function of the lawn mower is performed by the subassembly that includes the Vietnamese motor, base and cutting blades. It is the movement of the blade, powered by the motor and housed in the specially designed base, that contributes to the main functionality of the lawn mower (i.e. to cut grass). |
| Ruling Date: Aug. 7, 2025 |
N351505: The country of origin of an air inflator
| Origin: Vietnam |
| Item: The Air Inflator is described as a device used to inflate tires, sports equipment, air mattresses and other inflatable items. The rectangular shaped inflator is portable and features a digital display, SOS technology, LED lights, a type C charging port, a power cord port and a USB-A output port. The final assembly of the inflator occurs in Vietnam using components from China and Vietnam. Prior to the final assembly, the plastic front and rear cases of the inflator are formed in Vietnam and the printed circuit board assembly (PCBA) is produced by soldering Chinese components onto a motherboard. The internal air cylinder of the inflator is also assembled in Vietnam, which begins by die casting a bracket and afterward riveting a bearing to this bracket. |
| Reason: The components are assembled together in Vietnam to produce a motorized air cylinder and a PCBA, which are combined with other components, such as Vietnamese manufactured front and rear cases, to form an air inflator. The assembly processes that occur in Vietnam, taken as a whole, are sufficiently complex and meaningful as to result in a substantial transformation. |
| Ruling Date: Aug. 7, 2025 |
N351578: The tariff classification of sleep apnea masks from China
| HTS: 9019.20.0000, 9817.00.96, free: “[o]zone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus; parts and accessories thereof.” |
| Item: Sleep apnea masks in multiple sizes. They act as an interface for CPAP (continuous positive airway pressure) devices or BiPAP (bilevel positive airway pressure) devices and deliver pressurized air therapy to patients with chronic sleep apnea. |
| Reason: The sleep apnea masks are parts of the CPAP or bi-level systems without which the devices cannot function and thus are eligible for duty-free treatment under subheading 9817.00.96, Harmonized Tariff Schedule of the U.S. |
| Ruling Date: Aug. 7, 2025 |