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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.

N351444: The country of origin of Methenamine Hippurate Tablets, USP

Origin: India
Item: Methenamine Hippurate, imported in 1 gram tablets, is a urinary tract antiseptic and antibacterial drug. It is used for the prophylaxis and treatment of frequently recurring urinary tract infections requiring a long-term therapy. The active pharmaceutical ingredient (API), Methenamine Hippurate, is manufactured in India and that the finished tablets in dosage form are also made in India.
Reason: The active ingredient Methenamine Hippurate is made in India and the mixing of the API with the inactive ingredients into the final tablets is also made in India.
Ruling Date: Aug. 12, 2025

N351475: The tariff classification of stainless steel items from China

HTS: (Neck Tube Ring, Part #1, Neck Tube Short, Part #2) 7326.90.8688, 9903.01.24, 9903.81.90, 9903.01.33, 9903.88.03, 9817.00.96, free, “Other articles of iron or steel: Other: Other: Other: Other: Other.” (Long Neck Tube, Part #3) 7304.41.6045, 9903.01.24, 9903.01.33, 9903.88.15, 9817.00.96, free, “tubes, pipes and hollow profiles, seamless, of iron (other than cast iron) or steel: other, of circular cross section, of stainless steel: cold-drawn or cold-rolled (cold-reduced): other: other: other.”
Item: The three items under consideration will be incorporated into various models of the Caire Liberator Liquid Oxygen Reservoir (Liberator) after importation. You describe the Liberator as a proprietary, prescription-only device intended to store and supply supplemental oxygen to patients suffering from a variety of chronic diseases including heart, lung, and other respiratory conditions such as chronic obstructive pulmonary disease (COPD). The specific components at issue are a Neck Tube Ring, Part #1; a Neck Tube Short, Part #2; and a Long Neck Tube, Part #3.
Reason: N/A
Ruling Date: Aug. 12, 2025

N351552: The country of origin of Baby Wipes

Origin: Korea
Item: Nonwoven baby wipes, impregnated with a liquid soap preparation. The concentrated liquid soap is produced in South Korea with ingredients sourced from South Korea, Indonesia, Holland, and China. The concentrated liquid soap is transported from South Korea to a finishing and packaging facility in China, where the soap concentrate is diluted with water and pH-balanced with a small amount of citric acid, which does not result in a chemical reaction. The diluted solution is then impregnated onto nonwoven fabric, cut to specific dimensions, packaged into the final product, and shipped to the United States.
Reason: The liquid soap preparation imparts the finished product’s essential character, and the nonwoven material serves as the carrier. In China, the dilution, impregnating, cutting, and packaging processes do not result in a substantial transformation of the concentrated liquid soap preparation.
Ruling Date: Aug. 12, 2025

N351676: The tariff classification of a sensor detector and a radiation source from Japan

HTS: 9022.90.9500, 9903.02.30, 1.4% + 15%, “[a]pparatus based on the use of X-rays or of alpha, beta, gamma or other ionizing radiations whether or not for medical, surgical, dental or veterinary uses, including radiography or radiotherapy apparatus, X-ray tubes and other X-ray generators, high tension generators, control panels and desks, screens, examination or treatment tables, chairs and the like; parts and accessories thereof: [o]ther, including parts and accessories: [o]ther: [o]ther: [o]ther.”
Item: Sensor detectors and a radiation source, which are two components of the beta-ray sensor in the WEBFREX3ES, an online thickness gauge measurement system for battery electrode sheets. In the condition as imported, the sensor detector consists of a face plate, an ionization chamber, and detection electronics. The radiation source contains krypton 85 with a quantity of 15.4 GBq or 37 GBq based on the specification in a special sealed container inside a source assembly, which consists of a shielding, a shutter assembly, a face plate, and electrons for control.
Reason: N/A
Ruling Date: Aug. 12, 2025

N351692: The tariff classification of snap hooks from multiple countries

HTS: (brass snap hooks) 7419.80.5050, 9903.78.01, 9903.01.32, free + 50%, (non-copper: 9903.78.02), “Other articles of copper: Other: Other: Other: Other.” (zinc snap hooks) 7907.00.6000, 9903.01.32, 3%, “Other articles of zinc: Other.”
Item: The items under consideration are four models of snap hooks which will be used as connection hardware. Model 1 (from Malaysia, Taiwan, or Vietnam) is composed of brass (61% copper, 35% zinc, 4% other material) and the remaining three are composed of diecast zinc, and from Taiwan.
Reason: N/A
Ruling Date: Aug. 12, 2025

N351696: The tariff classification of rope clamps and snap hooks from multiple countries

HTS: (brass rope clamps and snap hooks) 7419.80.5050, 9903.78.01, 9903.01.32, free + 50% (non-copper: 9903.78.02), “Other articles of copper: Other: Other: Other: Other.” (zinc snap hooks) 7907.00.6000, 9903.01.32, 3%, “Other articles of zinc: Other.”
Item: The first items under consideration are described as rope clamps from Malaysia, Taiwan, or Vietnam, which are composed of brass (61% copper, 35% zinc, 4% other material). The second items under consideration are described as snap hooks which will be used as connection hardware. Model 1 (from Malaysia or Vietnam) is composed of brass (61% copper, 35% zinc, 4% other material) and model 2 (from Taiwan) is composed of diecast zinc, with nickel finish.
Reason: N/A
Ruling Date: Aug. 12, 2025

N351850: The classification of nonalloy steel billets from China

HTS: 7207.11.0000, 9903.01.24; 9903.81.87; 9903.01.33; 9903.91.01, free + 20% + 50% + 25%, “Semifinished products of iron or nonalloy steel: Containing by weight less than 0.25 percent of carbon: Of rectangular (including square) cross section, the width measuring less than twice the thickness.”
Item: The products to be imported are nonalloy steel billets measuring 3 inches in width x 3 inches in thickness x 12 inches long and contain less than 0.25% by weight of carbon. After importation, the billets will be used as a raw material for making steel in foundries.
Reason: N/A
Ruling Date: Aug. 11, 2025

N351866: The tariff classification of hot tap and line stop equipment from Spain

HTS: 8479.89.9599, 9903.02.20, 2.5% + 15%, “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.”
Item: The imported mechanical equipment is used to perform hot taps and line stops in “live” (pressurized) oil and gas pipelines without service interruption. Hot taps involve drilling or cutting a hole in an existing pipeline using a hot tap drilling machine to add new connections and branches to the pipeline without shutting down the system or interrupting the flow of the product. Line stops and completion operations, performed by line stop and completion machines, are used when it is necessary to isolate a section of the pipeline by temporarily blocking the flow, typically for pipeline repairs, replacements or modifications.
Reason: N/A
Ruling Date: Aug. 12, 2025

N351958: The country of origin of a combination square

Origin: Vietnam
Item: The item under consideration is described as a combination square, which is a measuring tool mainly consisting of a ruler and a square. The ruler is made of stainless steel, and the square is made of zinc alloy. The Vietnamese components include the square and the ruler, while the Chinese components include the bubble level, spring, adjustable screw and nut, bolt and plastic cap.
Reason: The device becomes a measuring device when substantially transformed in Vietnam by laser engraving the measurements onto the ruler. Additionally, the square is die casted in Vietnam which created the shape and character of the square. Once the ruler, with its engraved measurements and die cast square are sent to China for final processing they cannot be used for any other purpose than that of a measuring combination square.
Ruling Date: Aug. 12, 2025

N351287: The tariff classification and eligibility under the Nairobi Protocol of furniture components from Mexico and China.

HTS: (Chinese metal frame kits) 9403.99.9010, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Other furniture and parts thereof: Parts: Other: Other: Other: For toddler beds, cribs, bassinets and cradles.” (Chinese swivel caster wheel kit if constructed plastics) 9403.99.3005, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Other furniture and parts thereof: Parts: Other: Other: Of rubber or plastics: Of reinforced or laminated plastics: For toddler beds, cribs, bassinets, and cradles.” (Chinese swivel caster wheel kit if not constructed of plastics) 9403.99.4005, 9903.01.24, 9903.01.25, 9903.88.03, free + 20% + 10% + 25%, “Other furniture and parts thereof: Parts: Other: Other: Of rubber or plastics: Other: For toddler beds, cribs, bassinets, and cradles.” (Mexican textile and mesh canopy kit and the textile safety sheet kit) 9403.99.5005, 9903.01.27, 9903.01.01, free + 25%, “Other furniture and parts thereof: Parts: Other: Other: Of textile material, except cotton: For toddler beds, cribs, bassinets and cradles.”
Item: The “CubbyBed,” is a steel bedframe and textile canopy enclosure that consists of 6 component kits (3 metal frame kits, 1 swivel caster wheel kit, 1 textile and mesh canopy kit, 1 textile safety sheet kit.
Reason: N/A
Ruling Date: Aug. 11, 2025