Newly Released CBP HQ Rulings Dec. 5
The Customs Rulings Online Search System (CROSS) was updated on Dec. 5 with the following headquarters rulings (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):
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H332747: Application for Further Review of Protest No. 1704-22-105446; Tariff classification of certain Electronic Time Clocks
| Ruling: The CT74-X Electronic Time Clock will be classified under 8543.70.99 (2020 and 2021), which provides for, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other.” |
| Issue: Whether the CT74-X Electronic Time Clock is properly classified as an automatic dataprocessing (ADP) machine under Harmonized Tariff Schedule heading 8471 or as an other electrical machine or apparatus having an individual function under HTS heading 8543. |
| Item: Lathem Time's CT74-X Electronic Time Clock from China |
| Reason: Based on the description of the merchandise, the CT74-X is properly classified under heading 8543. The CT74-X is an electrical machine with an individual function, namely data collection, that is not provided for elsewhere in the HTSUS. The Explanatory Notes for heading 8543 also support finding the CT74-X’s data collection capabilities as its individual function as it “perform[s] [the function] distinctly from and independently of any other machine or appliance.” |
| Ruling Date: Oct. 3, 2025 |
H346945: USMCA Eligibility; Country of Origin Marking; Section 301 Measures; Task Chairs
| Ruling: The chairs qualify for preferential tariff treatment under the USMCA when imported into the U.S. The country of origin of the chairs will be Mexico, and Section 301 duties will not apply. |
| Issue: Whether the chairs will be eligible for preferential tariff treatment under the USMCA, and what is the country of origin of the chairs for purposes of marking and Section 301 trade remedies. |
| Item: Veyer's MFTC 200 Multi-Function Task Chair, which is manufactured in Mexico and imported into the U.S. |
| Reason: The bill of materials includes the total costs of the originating and non-originating materials, as well as the production costs. Based on the provided bill of materials, the net cost of the chairs is $68.87. The bill of materials indicates that the value of the non-originating materials is $32.42. Here, based on information provided by Veyer, the regional value content under the net cost method is 52.9%, which is above the amount required under the change in tariff classification rules of GN 11(o). Therefore, since the tariff shift requirements of GN 11 are satisfied, the chairs are eligible for preferential tariff treatment under the USMCA. For the country of origin, CBP believes the seat back provides the essential character of the mesh chairs. The foam and mesh for the seat back are cut and sewn in Mexico. The seat back makes up a large portion of the chair, and the seat back is also what renders the chair usable as a task chair and not just as a stool. For Section 301 trade remedies, the assembly of the chairs in Mexico is a substantial transformation. The mesh fabric is cut to shape and sewn; the wood components are drilled and riveted; the backrest frame, decorative cover, and gas lift are molded from plastic; the foam is cut to shape; and the rubber strips are cut to specific lengths. The Mexican manufacturer modifies the components of the chairs and does not simply assemble components with a predetermined use. |
| Ruling Date: Nov. 17, 2025 |
H342978: USMCA; Automotive Windshield
| Ruling: The automotive windshield qualifies for preferential tariff treatment under the USMCA. |
| Issue: Whether the automotive windshield is eligible for USMCA preferential tariff treatment. |
| Item: Cristales Inastillables de Mexico's automotive windshield, which will be used as original equipment in the manufacture of the Volkswagen ID Crozz SUV. The automotive windshield is produced in Mexico before being sent to the U.S. for assembly into the vehicle. |
| Reason: Since none of the non-originating components are classified under Harmonized Tariff Schedule heading 8708, the automotive windshield meets the tariff shift requirement of GN 11(o)/87.25(A). |
| Ruling Date: Nov. 24, 2025 |