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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N352233: The tariff classification and country of origin of a drive socket, a drive bit socket, an impact socket, an impact socket adapter and a spark plug socket
| HTS: (Drive socket, impact socket and the spark plug socket) 8204.20.0000, 9%, “hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); socket wrenches, with or without handles, drives or extensions; base metal parts thereof: socket wrenches, with or without handles, drives and extensions, and parts thereof.” (Drive bit socket) 8207.90.6000, 4.3%, “interchangeable tools for hand tools, whether or not power operated, or for machine-tools (for example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling, turning or screwdriving), 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, 3.9%, “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. It 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. It is a two-piece tool that comprises a bit holder socket with a press-fit bit. The bit holder socket allows the tool to be attached to a square driver of a wrench, ratchet handle, or power tool. An impact socket. It 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. It is a tool attachment that allows the use of sockets or bits with tools like impact drivers or drills. A spark plug socket. It 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. |
| Reason: The raw steel is substantially transformed in Vietnam into finished tools. |
| Ruling Date: Aug. 11, 2025 |
N351172: The eligibility under the United States-Mexico-Canada Agreement (USMCA) of an oven burner for the gas range from Mexico
| USMCA Eligibility: Yes |
| Item: The oven burner consists of a steel pipe, two assembly brackets, an ignition bracket, a shutter, and two screws. There will be two component sourcing/manufacturing scenarios. In the first scenario, all components are sourced from China (of Chinese origin). In the second sourcing/manufacturing scenario, the steel pipe and the screws will be made in Mexico, and the balance of the components will be imported from China. |
| Reason: The oven burner in both sourcing/manufacturing scenarios described above qualifies for USMCA preferential tariff treatment, it meets the requirements of General Note 11(b)(iii) since the non-originating components and materials undergo the prescribed tariff shift. |
| Ruling Date: Aug. 8, 2025 |
N351250: The tariff classification of FreeFlow ankle-foot orthosis (AFO) from an undisclosed country
| HTS: 9021.10.0090, 9817.00.96, free, “[o]rthopedic appliances …: [o]rthopedic or fracture appliances, and parts and accessories thereof: [o]ther.” |
| Item: Elevate FreeFlow Ankle-Foot Orthosis (AFO) is specially designed to help patients with drop foot and reduced dorsiflexion. It consists of a footplate and lateral-posterior strut made from carbon fiber, a calf cuff, a CoolFlow liner fitting into the interior of the cuff, and a calf strap equipped with a BOA Fit System for one-handed donning and doffing. |
| Reason: N/A |
| Ruling Date: Aug. 8, 2025 |
N351296: The tariff classification of collated steel nails from Oman
| HTS: (Paper Collated Galvanized Nails) 7317.00.5508, 9903.81.89, 9903.01.25, free + 50% + 10%, “Nails, tacks, drawing pins, corrugated nails, staples… and similar articles, of iron or steel, whether or not with heads of other materials, but excluding such articles with heads of copper: Other: Of one piece construction: Made of round wire… Collated nails: Other: Assembled in a paper strip.” (Plastic Collated Bright Nails) 7317.00.5507, 9903.81.89, 9903.01.25, free + 50% + 10%, “Nails, tacks, drawing pins, corrugated nails, staples… and similar articles, of iron or steel, whether or not with heads of other materials, but excluding such articles with heads of copper: Other: Of one piece construction: Made of round wire… Collated nails: Other: Assembled in a plastic strip: Other.” (Wire Coil Bright Nails) 7317.00.5503, 9903.81.89, 9903.01.25, free + 50% + 10%, “Nails, tacks, drawing pins, corrugated nails, staples… and similar articles, of iron or steel, whether or not with heads of other materials, but excluding such articles with heads of copper: Other: Of one piece construction: Made of round wire… Collated nails: Other: Assembled in a wire coil: Other.” (Brad Nails) 7317.00.5518, 9903.81.89, 9903.01.25, free + 50% + 10%, “Nails, tacks, drawing pins, corrugated nails, staples… and similar articles, of iron or steel, whether or not with heads of other materials, but excluding such articles with heads of copper: Other: Of one piece construction: Made of round wire… Collated nails: Other: Other.” |
| Item: Paper Collated Galvanized Nails. These nails are made of one-piece construction from galvanized (zinc coated) carbon steel wire, coated using zinc spray and vinyl, and collated using paper tape. Plastic Collated Bright Nails. These nails are made of one-piece construction from drawn carbon steel wire, coated using vinyl, and collated using plastic materials and coloring material. Wire Coil Bright Nails. These nails are made of one-piece construction from drawn carbon steel wire, coated using vinyl, and collated using copper-coated steel wire. Brad Nails. These nails are made of one-piece construction from galvanized (zinc coated) drawn wire, and collated using glue. |
| Reason: N/A |
| Ruling Date: Aug. 8, 2025 |
N351458: The tariff classification of a shell and tube heat exchanger from Canada
| HTS: 8419.50.5000, 9903.01.26, 9903.01.10, free + 35%, “Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of 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: Heat exchange units: Other.” |
| Item: The merchandise under consideration is referred to as a Slop Rerun Heater and is described as a shell and tube heat exchanger. It is installed in the 331B Module, a building module that will be incorporated into the Nanushuk oil processing facility in Alaska. |
| Reason: N/A |
| Ruling Date: Aug. 8, 2025 |
N351562: The tariff classification of a dust cover and sockets from South Korea
| HTS: (socket) 8708.80.6590, 9903.94.05, 9903.01.33, 2.5% + 25%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” (dust cover) 8708.99.8180, 9903.02.56, 2.5% + 15%, “Parts and accessories of the motor vehicles of headings 8701 to 8705: Other parts and accessories: Other: Other: Other: Other: Other: Other.” |
| Item: The first item is described as a dust cover for passenger vehicles, which is a stamped circular metal shield with a central hole for alignment between the wheel hub and steering knuckle. The second item is described as a socket, which is made of carbon steel which is formed into a specific shape and designed to fit in the mounting point of the steering knuckle for lower control arm. |
| Reason: N/A |
| Ruling Date: Aug. 8, 2025 |
N351608: The tariff classification of RVU305 in bulk form, from China
| HTS: 2934.99.3900, 9817.85.01, 6.5%, “Nucleic acids and their salts, whether or not chemically defined; other heterocyclic compounds: Other: Other: Aromatic or modified aromatic: Other: Other: Products described in additional U.S. note 3 to section VI.” |
| Item: RVU305 is an MTA-cooperative PRMT5 inhibitor that selectively impedes the growth of cancer cells with MTAP deletions, while sparing normal cells. The RVU305 will be undergoing drug development in the pre-IND stage for use in Phase 1 clinical studies. The RVU305 will be imported in bulk form and formulated into dosage form tablets for first-in-human, Phase I clinical studies on solid tumors. |
| Reason: The RVU305 will be imported solely for use in Phase 1 clinical studies. It will be imported in approximately 10 kg in limited non-commercial quantities solely for use in clinical trials. |
| Ruling Date: Aug. 8, 2025 |
N351651: The country of origin of novelty sunglasses
| Origin: Cambodia |
| Item: Bunny Glasses. The subject glasses consist of green or blue tinted polycarbonate lenses that are in the shape of a bunny. Chinese polycarbonate granules are melted and the lenses and temples are created via an injection molding process in Cambodia. The temples are attached via a screw before the finished glasses are packaged for shipment to the United States. |
| Reason: The polycarbonate granules are substantially transformed by the injection molding process performed in Cambodia. |
| Ruling Date: Aug. 8, 2025 |
N352065: The tariff classification of bullets from South Africa
| HTS: 9306.30.8000, 9903.02.55, free + 30%, “Bombs, grenades, torpedoes, mines, missiles and similar munitions of war and parts thereof; cartridges and other ammunition and projectiles and parts thereof, including shot and cartridge wads: Other cartridges and parts thereof: Other.” |
| Item: The items under consideration are described as complete metal jacket (CMJ) bullets of various shapes, sizes, and grain which will be used to manufacture ammunition after importation into the United States. The bullets consist of a lead-antimony alloy core completely coated in pure copper. |
| Reason: N/A |
| Ruling Date: Aug. 8, 2025 |
N351307: The country of origin of water and blood filters
| Origin: U.S. |
| Item: The items under consideration are described as water and blood filters. The water filter products are used to filter dialysis water, pharmaceutical water, domestic water, and wastewater. The blood filter products are used to filter blood and plasma. U.S.-origin Fiber Bundles and Tunisian-origin plastic parts and components are exported to Italy for further processing into the finished merchandise. |
| Reason: The assembly process performed in Italy predominantly involves placing the U.S.-origin Fiber Bundles into Tunisian-origin plastic parts and components. The Fiber Bundles provide the essential function of the filters, as it is the Fiber Bundles from the United States which require considerable technical expertise and customized equipment to produce. It is also the most expensive portion of the filter, and it is the item performing the filtering of the water or blood. |
| Ruling Date: Aug. 7, 2025 |