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.
N352297: The tariff classification of an automobile power line communication module from South Korea
| HTS: 8517.62.0090, 9903.01.32, free, “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network)…: Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” |
| Item: This product is installed in the center of an electric vehicle’s cowl crossbar, and is composed of a printed circuit board assembly (PCBA) within a plastic housing. This module is used to facilitate the transmission of battery charging status within an automobile. |
| Reason: N/A |
| Ruling Date: Aug. 20, 2025 |
N352533: The tariff classification of an automobile seat component from South Korea
| HTS: 9401.99.1085, 9903.02.56, free + 15%, “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Parts: Other: Of seats of a kind used for motor vehicles: Other.” |
| Item: A composite seat component constructed of aluminum and steel metal, injection molded plastic, leather, rubber, foam, and non-woven fabric that will be installed adjacent to the driver and front passenger automobile seat of motor vehicles according to Original Equipment Manufacturer specifications. |
| Reason: N/A |
| Ruling Date: Aug. 20, 2025 |
N351075: The eligibility under the United States-Mexico-Canada Agreement (USMCA) of oven latch assemblies from Mexico and China
| USMCA Eligibility: Yes |
| Item: The latch assemblies are parts of gas-electric ranges for domestic use. There are four manufacturing scenarios, in which the oven latch assemblies are fabricated with components of both Chinese-origin and Mexican-origin. In Scenarios 1, 2 and 4, the factory in Mexico will produce certain components from China and assemble them with the Mexican-origin components to make the finished oven latch assemblies. In Scenario 3, the Mexican-origin component will be shipped to China and the factory in China will assemble the Mexican-origin component with the Chinese-origin components to make the finished products. |
| Reason: All non-originating components and materials undergo the prescribed tariff shift. |
| Ruling Date: Aug. 19, 2025 |
N351523: The country of origin and marking of BBC Beauty® Lip Balm
| Origin: Malaysia or Vietnam |
| Item: The subject product is described as a lip balm sold under the brand name BBC Beauty®, designed to intensely protect and care for lips. The raw materials used to produce the finished lip balm will be sourced from various countries. The ingredients will be sent to either Malaysia or Vietnam for processing. In Malaysia or Vietnam, the ingredients will be weighed and blended under controlled conditions to produce a stable bulk. This includes heating oil and wax in separate phases, then combining the ingredients using a mixing machine. Preservatives and other ingredients will then be added. |
| Reason: The production process in Malaysia or Vietnam results in a substantial transformation of the raw materials into the bulk cosmetic. |
| Ruling Date: Aug. 19, 2025 |
N351524: The country of origin of Johnson Parker® Spiced Cranberry Scented Body Butter with Shea Butter
| Origin: Malaysia or Vietnam |
| Item: The subject product is described as Johnson Parker® Spiced Cranberry Scented Body Butter with Shea Butter packaged for retail sale in an 8 fluid ounce tube. The ingredients include emulsifiers, preservatives, fragrances, oils, solvents, and moisturizing agents sourced from various countries. The ingredients will be sent to either Malaysia or Vietnam where they will be weighed, emulsified, homogenized, and blended under controlled conditions to produce a stable bulk using a mixing machine (emulsifier). |
| Reason: The production process in Malaysia or Vietnam results in a substantial transformation of the raw materials to produce the body butter. |
| Ruling Date: Aug. 19, 2025 |
N351528: The country of origin of Frozen Octopus
| Origin: Morocco |
| Item: The subject merchandise is Frozen Octopus (Octopus vulgaris), which is harvested in the territorial waters of Morocco and Mauritania. After harvest, the octopus is transported in refrigerated vehicles to processing facilities located in Morocco and Mauritania. At these facilities, the mollusks are sorted by weight and quality, then frozen, packed, and exported to Spain for cleaning and processing. |
| Reason: Since the octopus in question is harvested within the territorial waters of Morocco and Mauritania, the special rule applies, and origin is determined by the coastal country of harvest. The subsequent processing in Spain (thawing, washing, hydration, refreezing, and packaging) does not constitute a substantial transformation. |
| Ruling Date: Aug. 19, 2025 |
N351539: The tariff classification of hardware packs from China
| HTS: (mattress retainers) 8302.42.3065, 9903.01.24, 9903.01.25, 3.9% + 20% + 10%, “Base metal mountings, fittings and similar articles… Other mountings, fittings and similar articles, and parts thereof: Other, suitable for furniture: Of iron or steel, of aluminum or of zinc; Other.” (Hex screws) 7318.15.8045, 9903.01.24, 9903.81.90, 9903.01.33, 9903.88.03, 8.5% + 20% + 50% + 25%, “Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Other screws and bolts, whether or not with their nuts or washers: Other: Having shanks or threads with a diameter of 6 mm or more… Other: Socket screws: Other.” (Screws) 7318.14.1060, 9903.01.24, 9903.81.90, 9903.01.33, 9903.88.03, 6.2% + 20% + 50% + 25%, “Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Threaded articles: Self-tapping screws: Having shanks or threads with a diameter of less than 6 mm… Other.” (Pin and Cable) 7318.29.0000, 9903.01.24, 9903.81.90, 9903.01.33, 9903.88.03, 2.8% + 20% + 50% + 25%, “Screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: Non-threaded articles: Other.” (Plastic Clamps) 3926.90.9989, 9903.01.24, 9903.01.25, 9903.88.15, 5.3% + 20% + 10% + 7.5%, “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” (4 mm hex wrench) 8204.11.0060, 9903.01.24, 9903.01.25, 9903.88.03, 9% + 20% + 10% + 25%, “Hand-operated spanners and wrenches (including torque meter wrenches but not including tap wrenches); Socket wrenches, with or without handles, drives and extensions; base metal parts thereof: hand-operated spanners and wrenches, and parts thereof: Nonadjustable, and parts thereof: Other (including parts).” |
| Item: Hardware packs for the assembly of long term beds. |
| Reason: N/A |
| Ruling Date: Aug. 19, 2025 |
N351582: The classification, marking, and country of origin of two dryer vent cleaning kits from Vietnam
| HTS: 9603.90.8050, 9903.02.69, 2.8% + 20%, “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther: [o]ther: [o]ther.” |
| Origin: Vietnam |
| Item: Two kits, consisting of brushes and parts for extension handles. The brushes are made in Vietnam. |
| Reason: As these two kits are considered sets, the country of origin for both would be provided by the source country for the vent brushes, which is Vietnam. |
| Ruling Date: Aug. 19, 2025 |
N351805: The tariff classification of a coolant hub module from South Korea
| HTS: 8413.70.2005, 9903.02.56, free + 15%, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Other centrifugal pumps: Other: Other: Single-stage, single-suction, close-coupled: With discharge outlet under 5.08 cm in diameter.” |
| Item: The product at issue is a coolant hub module, which is referred to as a vehicle coolant reservoir. The module, which is part of a cooling system used in an electric vehicle, is a composite good that consists of two single suction water pumps, a reservoir with a 2.2. liter capacity, a three-way valve, and various hoses and mounting brackets. In use, the closed coupled pumps discharge coolant stored in the reservoir out of 1.89-centimeter outlets to dissipate heat released by the battery system and various electrical systems. |
| Reason: The pumps impart the essential character of the module, as they release coolant that lowers the temperature of various systems. |
| Ruling Date: Aug. 19, 2025 |
N351860: The country of origin of a heat pump
| Origin: China |
| Item: The heat pump (Model No. GDHP65036TC3) primarily consists of a chassis that encases a compressor, a heat exchange unit, a motor and fan assembly, valve assemblies, a control panel and an accumulator. Once paired with an indoor unit, which is imported separately, the system heats and cools spaces. With respect to origin, the final assembly occurs in South Korea using components from China. |
| Reason: A heat exchange unit produced in South Korea is assembled with components sourced from China, such as a compressor and a chassis, in South Korea to produce a heat pump. The steps that occur during the final assembly process are not complex, as they consist of processes such as screwing, bolting and brazing, which is recognized as a welding operation used to join pipes to heat exchangers. |
| Ruling Date: Aug. 19, 2025 |