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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N352312: The tariff classification of a Portable Restroom Trailer from China
| HTS: 8716.10.0030, 9903.88.03; 9903.01.25, free + 10% + 10%, “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Trailers and semi-trailers for housing or camping: Less than 10.6m in length” |
| Item: The item under consideration has been identified as a portable restroom trailer. The trailer has been equipped with an external power source connection to power the restrooms. The portable restroom trailer is designed and intended to be used at outdoor gatherings like festivals and weddings. |
| Reason: N/A |
| Ruling Date: Aug. 18, 2025 |
N351480: The tariff classification of Brivaracetam Tablets and Eltrombopag Tablets in dosage form, from India
| HTS: (Brivaracetam) 3004.90.9236, 9903.01.32, free, “Medicaments … consisting of mixed or unmixed products for therapeutic or prophylactic uses, put up in measured doses … or in forms or packings for retail sale: Other: Other: Other: Medicaments primarily affecting the central nervous system: Anticonvulsants, hypnotics and sedatives.” (Eltrombopag) 3004.90.9221, 9903.01.32, free, “Medicaments… consisting of mixed or unmixed products for therapeutic or prophylactic uses, put up in measured doses … or in forms or packings for retail sale: Other: Other: Other: Cardiovascular medicaments: Other.” |
| Item: The first product, Brivaracetam, imported in dosages of 10 mg, 25 mg, 50 mg, 75 mg and 100 mg tablets, is an anticonvulsant drug. It is indicated for the treatment of partial-onset seizures in patients 1 month of age and older. The second product, Eltrombopag, imported in 12.5 mg, 25 mg, 50 mg, and 75 mg tablets, is a thrombopoietin receptor agonist. It is indicated for treatment of thrombocytopenia (low blood platelet counts) in patients with persistent or chronic immune thrombocytopenic, thrombocytopenia in patients with chronic hepatitis C infection, and patients with severe aplastic anemia. |
| Reason: N/A |
| Ruling Date: Aug. 15, 2025 |
N351492: The Tariff Classification and Country of Origin of Frozen Squid
| HTS: 0307.43.0050, 9903.01.25, free + 10%, “Molluscs, whether in shell or not, live, fresh, chilled, frozen, dried, salted or in brine; smoked molluscs, whether in shell or not, whether or not cooked before or during the smoking process; flours, meals and pellets of molluscs, fit for human consumption: Cuttlefish and squid: Frozen squid: Other: Other: Other.” |
| Origin: Peru |
| Item: Whole, frozen squid (Dosidicus gigas, also known as Humboldt squid) of Peruvian origin will be shipped to China. In China, the squid will be processed into strips, rings, and tentacles and individually quick frozen in bags for shipment to the United States. |
| Reason: The article is not substantially transformed due to processing that is performed in China. Accordingly, based on the information presented, the finished good is a product of Peru. |
| Ruling Date: Aug. 15, 2025 |
N351496: The tariff classification of landing gear parts for the front of a fifth wheel and commercial trailer from Canada
| HTS: 8716.90.5060, 9903.94.05; 9903.01.26, 3.1% + 25%, “Trailers and semi-trailers; other vehicles, not mechanically propelled; and parts thereof: Parts: Other: Other.” |
| Item: The driven leg landing gear parts are square, hot rolled, pickled and oiled steel tubes. In Canada, the driven leg landing gear parts are cut to-length, manufactured to specific customer tolerances, and laser-cut with holes. The landing gears are permanently attached to the underside of trailers and are used to lift and stabilize a vehicular trailer so that it may be disengaged from the fifth wheel of a tractor. |
| Reason: N/A |
| Ruling Date: Aug. 15, 2025 |
N351503: The country of origin of wire fan heaters
| Origin: Vietnam |
| Item: The items under consideration are wire fan heaters model numbers which are a fan/space heater combination that can generate heat and create airflow by moving air (without generating heat). The NF15 fan heaters are manufactured in Vietnam using raw materials and components originating from both Vietnam and China. |
| Reason: The Chinese components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial transformation. |
| Ruling Date: Aug. 15, 2025 |
N351504: The country of origin of positive temperature coefficient (PTC) fan heaters
| Origin: Vietnam |
| Item: The DR-HS heaters operate by using a positive temperature coefficient (PTC) heating element to heat air passing over the PTC heating element. The fan blade in the DR-HS heaters then circulates the heated air to the room or other surrounding area where the DR-HS heaters are located. The DR-HS heaters are produced in Vietnam using Chinese raw materials and Vietnam accounts for the majority or a significant portion of the production costs of the DR-HS heaters. |
| Reason: The Chinese components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial transformation. |
| Ruling Date: Aug. 15, 2025 |
N351538: The country of origin of an impeller and a diffuser
| Origin: Malaysia |
| Item: The diffuser and impeller are components of an Electric Submersible Pump (ESP) system used to lift crude oil from a wellbore. The manufacturing of the diffuser and impeller begins in China where they are cast into a casting tree that consists of groups of iron circles attached to a central gating system. Once imported into Malaysia, the castings of the diffuser and impeller are subject to shell treatment, an initial sandblasting phase, cutting and separation processes, a manual saw cutting process, a second sandblasting phase, two machining phases, and polishing and turning operations. |
| Reason: The Chinese castings undergo various processes in Malaysia to form a finished diffuser and impeller. It is in Malaysia that the vane profiles and the circular center hubs, which have an internal diameter discernable to a specific shaft, are formed. As such, the processes completed in Malaysia substantially transform the castings. |
| Ruling Date: Aug. 15, 2025 |
N351581: The tariff classification of gloves from Sri Lanka
| HTS: 6116.10.5520, 9903.02.57, 13.2% + 20%, “Gloves, mittens and mitts, knitted or crocheted: Impregnated, coated, covered or laminated with plastics or rubber: Other: Without fourchettes: Other: Containing 50 percent or more by weight of cotton, man-made fibers or other textile fibers, or any combination thereof: Subject to man-made fiber restraints.” |
| Item: A nitrile rubber dipped, string-knit work glove constructed of 85% nylon, 10% spandex, and 5% elastane. The glove features a nitrile rubber coating on the outer surface, which covers the entire palm, a portion of the palm side cuff and overlaps the backside fingertips and sides of the wearer’s hand and fingers. The glove also features an elasticized cuff finished with an overlock stitch at the bottom. |
| Reason: The essential character of the glove is imparted by the coated string knit portion and the weight of the textiles is more than 50% of the weight of the glove. |
| Ruling Date: Aug. 15, 2025 |
N351596: The country of origin of positive temperature coefficient (PTC) fan heaters
| Origin: Vietnam |
| Item: The PTC Heaters I operate by using a positive temperature coefficient (PTC) heating element to heat air as it passes over the PTC heating element. The fans in the PTC Heaters I then circulate the heated air to the room or other surrounding area where the PTC Heaters I are located. The PTC Heaters I are produced in Vietnam through a manufacturing and assembly process which accounts for the majority or a significant portion of the production costs of the PTC Heaters I. |
| Reason: The Chinese components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial transformation. |
| Ruling Date: Aug. 15, 2025 |
N351597: The country of origin of positive temperature coefficient (PTC) fan heaters
| Origin: Vietnam |
| Item: The PTC Heaters II operate by using a positive temperature coefficient (PTC) heating element to heat air as it passes over the PTC heating element. The fans in the PTC Heaters II then circulate the heated air to the room or other surrounding area where the PTC Heaters II are located. The PTC Heaters II are produced in Vietnam using raw materials and components originating from Vietnam, Thailand and China. |
| Reason: The Chinese-origin and the Thai-origin components undergo processing in Vietnam that is sufficiently complex and meaningful as to result in a substantial transformation. |
| Ruling Date: Aug. 15, 2025 |