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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N351647: The tariff classification of a nasal spray from Korea
| HTS: 3824.99.9397, 9903.01.32, 5%, “Prepared binders … chemical products and preparations … (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: …Other.” |
| Item: The merchandise in question is a nasal spray with the product name of LUCA V-Defense Nasal Spray. It is used to protect the nasal mucosa from infection by respiratory viruses and allergens by forming a physical barrier when sprayed into the nose. It consists of water and other ingredients. |
| Reason: N/A |
| Ruling Date: Aug. 15, 2025 |
N351814: The tariff classification of battery packs from China
| HTS: 8507.60.0020, 9903.01.24; 9903.01.25; 9903.88.15, 3.4% + 20% + 10% + 7.5%, “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Lithium-ion batteries: Other.” |
| Item: The merchandise under consideration is identified as battery packs for the R90 power assist device, a battery powered accessory for propelling manual wheelchairs. Each battery pack consists of cylindrical lithium-ion battery cells in a sealed housing with indicator LEDs and an electrical contact interface specific to the power assist device. |
| Reason: N/A |
| Ruling Date: Aug. 15, 2025 |
N352145: The tariff classification of an AC conversion platform from Vietnam
| HTS: 8504.40.9570, 9903.02.69, free + 20%, “Electric transformers, static converters and inductors…: Static converters: Other: Inverters.” |
| Item: The merchandise under consideration is identified as the Fluence SmartSkid, which is described as an Alternating Current (AC)-based energy storage platform. The subject device consists of AC conversion hardware, an HVAC system, a fire panel, and battery management electronics. |
| Reason: N/A |
| Ruling Date: Aug. 15, 2025 |
N352206: The tariff classification of a 1999 Subaru Sambar from Japan
| HTS: 8703.21.0150, 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 not exceeding 1,000 cc.: Other.” |
| Item: The item under consideration has been identified as a 1999 Subaru Sambar, chassis number is TV1-008356. The vehicle has the following specifications: Weight: 940 kg. Length: 339 cm Width: 147 cm Height: 190 cm Powered by a 650 Cubic Centimeter (cc) spark-ignition internal combustion piston engine. |
| Reason: N/A |
| Ruling Date: Aug. 15, 2025 |
N352283: The tariff classification of a 1993 Ferrari from Italy
| HTS: 8703.24.0190, 9903.94.04; 9903.02.20, 2.5% + 15%, “Motor cars and other motor vehicles principally designed for the transport of persons …, including station wagons and racing cars: Other vehicles, with only spark-ignition internal combustion piston engines: Of a cylinder capacity exceeding 3,000 cc: Other: Used.” |
| Item: The item under consideration has been identified as a 1993 Ferrari 348 TS. |
| Reason: N/A |
| Ruling Date: Aug. 15, 2025 |
N351368: The country of origin of a doorknob with an integral keyed lock
| Origin: China |
| Item: The merchandise under consideration is identified as a Mechanical Entry Door Lock, which consists of the internal and external doorknob assemblies, lock cylinder, strike plate, latch, keys, and hardware. The article is used for entry doors such as front entry doors, garage doors and kitchen doors. |
| Reason: The internal and external doorknobs impart the essence to this subject good. The doorknob assemblies produced in China are not substantially changed by either the addition of the Vietnamese components that primarily provide the locking capability or the minor assembly operations performed in Vietnam. |
| Ruling Date: Aug. 14, 2025 |
N351497: The tariff classification of Hemodialysis System Console components from China
| HTS: (pressure sensor) 9026.20.4000, 9817.00.96, free, “Instruments and apparatus for measuring or checking the flow, level, pressure or other variables of liquids or gases (for example, flow meters, level gauges, manometers, heat meters), excluding instruments and apparatus of heading 9014, 9015, 9028 or 9032; parts and accessories thereof: For measuring or checking pressure: Electrical.” (power supply module) 8504.40.9540, 9817.00.96, free, “Electrical transformers, static converters…: Static converters: Other: Rectifiers and rectifying apparatus: Power Supplies: Other.” (Base, degas chamber) 9018.90.7570, 9817.00.96, free, “Instruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof: Other instruments and appliances and parts and accessories thereof: Other: Electro-medical instruments and appliances and parts and accessories thereof: Other: Other: Parts and accessories of dialysis instruments and apparatus.” |
| Item: The three items under consideration are all described as parts designed for the Tablo Hemodialysis System Console, which is the core component of the Outset Medical Tablo System, a mobile, all-in-one hemodialysis machine designed for use in various care settings, including hospitals and homes. It integrates water purification and dialysate production, eliminating the need for separate equipment. The first item under consideration is described as a pressure sensor, the second item under consideration is described as the power supply module and the third item under consideration is described as the Base, degas chamber. |
| Reason: N/A |
| Ruling Date: Aug. 14, 2025 |
N351580: The country of origin of a bottle jack
| Origin: Thailand |
| Item: The subject merchandise is a hydraulic bottle jack, and is described as a vertical hydraulic jack that utilizes a high-pressure cylinder and pump mechanism to lift objects. It is used during automotive repair as well as in industrial, farming, and construction applications. In the current manufacturing scenario, raw material, steel pipes, and steel bars will be manufactured into a base assembly, ram assembly, pump plunger assembly, handle assembly, and other components in Thailand. |
| Reason: Nearly all the components, including the ram assembly, base assembly, cylinder body, sleeves, pump body, and pump plunger, and more, are manufactured in Thailand. After processing, these critical components of the bottle jack emerge with a new name, character, and use, different from that possessed by the materials from which they were formed. |
| Ruling Date: Aug. 14, 2025 |
N351649: The country of origin of gaming laptops
| Origin: Vietnam |
| Item: The merchandise under consideration is identified as four models of automatic data processing (ADP) machines that are referred to as Razer Blade 14 Gaming Laptop personal computers (PCs), which are all laptops equipped with Windows 11 Home NextGen Premium operating system and Razer’s proprietary software called Razer Synapse. The motherboard Printed Circuit Board Assemblies (PCBAs) are assembled in Vietnam using components sourced from various countries of origin. |
| Reason: The assembly of the motherboard PCBA in Vietnam, via surface mount technology, laser etching, solder past application, accurate pick and placement of small components, and permanent connection of the components through a reflow oven results in a substantial transformation of those components to produce a motherboard PCBA of Vietnam origin. |
| Ruling Date: Aug. 14, 2025 |
N351672: The country of origin of motorcycle helmets
| Origin: Vietnam |
| Item: Full-face motorcycle helmets. The outer shell is constructed from injection-molded Acrylonitrile Butadiene Styrene (ABS) thermoplastic, while the inner lining consists of Expanded Polystyrene (EPS) foam. The helmets feature a wide-open face area, a rugged angular shape with a protruding chin bar, a padded interior, and integrated ventilation ports. The manufacturing process begins in Vietnam, where the outer shell of each helmet is produced through injection molding. The helmet is subsequently exported to China for further processing, which includes the installation of trim and accessories around the helmet edges, as well as the addition of vents, sliders and pressure plates. |
| Reason: The processing operations carried out in China do not result in a new or substantially transformed article of commerce with a different name, character or use from its individual components. Accordingly, in determining the country of origin of motorcycle helmets, primary consideration is given to the outer shell, which imparts the essential character of the product and constitutes its most significant and costly component. |
| Ruling Date: Aug. 14, 2025 |