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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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.
N352331: The tariff classification, country of origin, marking and eligibility for preferential treatment under the United States-Korea Free Trade Agreement (KORUS) of Seasoned Squid from South Korea
| HTS: 1605.54.6030, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Crustaceans, molluscs and other aquatic invertebrates, prepared or preserved: Cuttle fish and squid: Other: Squid: Other.” |
| Origin: China |
| KORUS: Not eligible |
| Item: Ready-to-eat banchandanji jeotgal (seasoned squid) composed of salted squid, starch syrup, red pepper powder, frozen minced garlic, paprika extract, sugar, frozen red chili pepper, fresh garlic, sesame seeds, mipung (umami seasoning blend), matsurae (flavor enhancer), ground ginger, anchovy fish sauce, glycine, xanthan gum, polymix-m (preservative blend) and compound phosphate. The manufacturing process involves cutting the squid into stripes, salting them and then blending them with the aforementioned seasoning ingredients. The squid is procured and salted in China, then exported to Korea. In Korea, it is mixed with a proprietary seasoning mix. |
| Reason: The processing described in Korea (the addition of the proprietary blend of seasonings) does not effect a substantial transformation. Accordingly, the squid retains its original country of origin as a product of China. Since the product is not from Korea, the United States-Korea Free Trade Agreement (KORUS) isn't applicable to this ruling. |
| Ruling Date: Sept. 12, 2025 |
N352389: The country of origin of Fish Oil
| Origin: Peru |
| Item: Fish oil derived in Peru from anchovies (Engraulis ringers) harvested in Peru. The fish oil is subsequently exported to China, where the oil undergoes multiple refining processes, including esterification, molecular distillation, winterization, mixing, bleaching and deodorization. During processing, vitamin E of Chinese origin is added, resulting in a composition of approximately 99.8% fish oil and 0.2% vitamin E. The finished product will be shipped to the United States in drums, where it will undergo encapsulation. |
| Reason: Neither the processing described in China (esterification, molecular distillation, winterization, mixing, bleaching, and deodorization) nor the addition of Chinese origin vitamin E, effects a substantial transformation. Accordingly, the fish oil retains its original country of origin as a product of Peru. |
| Ruling Date: Sept. 12, 2025 |
N352638: The country of origin of filter cartridges
| Origin: United Arab Emirates |
| Item: Filter cartridges, which are devices designed specifically for use in applications requiring hydrogen separation from hydrogen-based gas streams. The filter cartridges are intended to process gas mixtures from refineries, chemical, and petrochemical plants. Each gas filtration cartridge is manufactured in the UAE from components from Russia, Germany, China, the U.S., and the UAE. The polymer fiber is produced in Russia while the bushing is made in Germany. The U.S. components include the amorphous fluoropolymer, heat-transfer and electronics-testing fluid, resin, epoxy, and curing agent. The Chinese components include the mandrel screen, cap screen and pot screen. Finally, the UAE components include the machined mandrel, solid pot plug, cap end insert, and various O-rings. |
| Reason: The manufacturing and assembly process performed in the UAE is considered complex. Numerous steps are needed to transform the individual components from Russia, China, Germany, and the U.S. into a filter cartridge in the UAE. The individual components each have a change in name, character, and use. |
| Ruling Date: Sept. 12, 2025 |
N352651: The tariff classification of a 1999 Toyota Crown from Japan
| HTS: 8703.23.0190, 9903.94.04, 9903.02.30, 2.5% + 15%, “Motor cars and other motor vehicles principally designed for the transport of persons (other than those of heading 8702), including station wagons and racing cars: Other vehicles, with only spark-ignition internal combustion piston engines: Of a cylinder capacity exceeding 1,500 cc but not exceeding 3,000 cc: Other: Used.” |
| Item: A used 1999 Toyota Crown from Japan. The car is a sedan designed for carrying five (5) passengers, including the driver. The vehicle is equipped with a Toyota JZ-series 6-cylinder (2997cc) spark-ignition internal combustion piston engine. |
| Reason: N/A |
| Ruling Date: Sept. 12, 2025 |
N352712: The tariff classification and country of origin of ball joints and Pitman arms
| HTS: (1) 8708.80.6590, 9903.94.05, 9903.01.33, 2.5% + 25% + 19%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Suspension systems and parts thereof (including shock absorbers): Parts: Other: Other: Other.” (2) 8708.94.7550, 9903.94.05, 9903.01.33, 2.5% + 25% + 19%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Steering wheels, steering columns and steering boxes; parts thereof: Parts: For other vehicles: Other: Other.” |
| Item: (1) Ball joints and (2) Pitman arms used in passenger vehicles. For the ball joints, the boot, housing, and ball pin are sourced from Malaysia. Other components such as the nut, bolt, glib, gasket, spiral and ball socket are imported from China. These imported components are then subject to multiple precision turning operations, riveting, greasing, and press-fitting in Malaysia to create a finished product. For the Pitman arms, the boot, housing and ball are sourced from Malaysia. Other components, such as the nut, bolt, glib, gasket and ball socket are imported from China. These imported components are then subject to precision turning, riveting, greasing, pressing, and other finishing operations in Malaysia before final assembly in Malaysia |
| Reason: Although the Pitman arms interact with the suspension systems, they are components of steering systems. As a result, they are more specifically provided for in subheading 8708.94 as parts of steering systems. The main components of the ball joints and Pitman arms are sourced from Malaysia. Furthermore, the Chinese components are further machined and integrated with the Malaysian components, thus, losing their individual identities and becoming parts of the finished articles. As a result, the substantial transformation occurs in Malaysia. |
| Ruling Date: Sept. 12, 2025 |
N352740: The tariff classification of a pocket spring unit for a mattress from Mexico
| HTS: 9404.29.9013, 9903.01.01, 9903.01.27, 6% + 25%, “Mattress supports; articles of bedding and similar furnishing (for example, mattresses, quilts, eiderdowns, cushions, pouffes and pillows) fitted with springs or stuffed or internally fitted with any material or of cellular rubber or plastics, whether or not covered: Mattresses: Of other materials: Other: Uncovered innerspring units: Of a width exceeding 91 cm, of a length exceeding 184 cm, and of a depth exceeding 8 cm.” |
| Item: A pocket spring unit intended for use as the core support component in a pocket coil mattress. The spring coils are made of steel wire, and are individually sealed in a nonwoven barrel shaped pocket composed of 100% polypropylene spunbonded fabric to form a spring coil pocket. Each spring unit is held together by gluing the barrel shaped fabric pockets to one another, forming a unified rectangular mattress core unit arranged in a grid format. |
| Reason: Mattress supports are items such as box springs that are designed to be placed under a mattress for support. The pocket spring support system is used in the manufacture of the mattress, rather than the mattress support; therefore, subheading 9404.90.1000 is not appropriate. |
| Ruling Date: Sept. 12, 2025 |
N352760: The tariff classification of sun visor extender from China
| HTS: 8708.29.5060, 9903.01.24, 9903.94.05, 9903.01.33, 20% + 25% + 25%, "Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories of bodies (including cabs): Other: Other: Other." |
| Item: A vehicle interior sun visor accessory, which is a sun visor extender for vehicles. |
| Reason: N/A |
| Ruling Date: Sept. 12, 2025 |
N352762: The country of origin of scissors from Vietnam
| Origin: Vietnam |
| Item: Three different types of scissors: heavy duty, non-slip soft-grip, and standard. They are all made with stainless steel cutting blades, a tension screw, and plastic comfort grips. In Vietnam the raw stainless steel is stamped into two blade blanks. At this stage, the blanks already exhibit their final shape, size, and form. In China the finger and assembly holes are punched, the blades are heat treated and sharpened, and the injection molded handles are attached. The scissors will then be packaged for retail sale. |
| Reason: The blade blanks hold the essential identity of these finished scissors and the further processing in China would not substantially transform them. |
| Ruling Date: Sept. 12, 2025 |
N352766: The country of origin of an automotive air filter
| Origin: Thailand |
| Item: An automotive air filter, which is 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 filter is assembled in Thailand using components from Thailand and China. The Thai components include the filter media, filter element, slitted media block, PP melt-blown microfiber and various packaging materials. The Chinese components include the fiber base paper, sealing adhesive, polyether polyol, isocyanate, polyester fiber, color box and label. |
| Reason: The manufacturing and assembly process performed in Thailand is considered complex. The primary filtering components, including the paper from China and the media from Thailand, need to be ultrasonically combined in Thailand. While many of the additional steps include simple assembly, the ultrasonic combining creates a new article with a new name, character, and use. Therefore, the country of origin of the automotive air conditioning filter is Thailand, which is where the fiber base paper and filter media is ultrasonically combined. |
| Ruling Date: Sept. 12, 2025 |
N352799: The tariff classification of springs from Japan
| HTS: (1), (2) and (3) 7320.20.5020,9903.81.90, 9903.01.33, 3.9% + 50% + 15%, “Springs and leaves for springs, of iron or steel: Helical Springs: Other: Helical springs, of wire having a cross-sectional dimension of less than 5.1 mm: Other.” (4) 7320.20.5045, 9903.81.90, 9903.01.33, 3.9% + 50% + 15%, "Springs and leaves for springs, of iron or steel: Helical Springs: Other: Helical springs, of wire having a cross-sectional dimension of 5.1 mm or more but less than 12.7 mm." |
| Item: Four models of helical oil tempered steel springs which will be used in automotive applications. (1) Valve springs used to control the opening and closing of intake and exhaust valves in automotive engines. (2) Damper springs (straight type), which will be used for vibration and torque fluctuation absorption in the lock-up clutch system of automotive engines. (3) Damper springs (arc type), which will also be used for vibration and torque fluctuation absorption in the lock-up clutch system of automotive engines. (4) Clutch piston return springs, which will be used for pressure application and as a return mechanism in automotive transmission clutch systems. |
| Reason: N/A |
| Ruling Date: Sept. 12, 2025 |