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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N352061: The country of origin of a freeze-on-demand food mixer
| Origin: China |
| Item: A freeze-on-demand food mixer, also referred to as the ColdSnap System, is a smart, connected, food-processing, mixer-freeze appliance with complex real-time control and remote monitoring, that can be used to create single-serve frozen desserts (ice cream, smoothies, lattes, protein shakes, cocktails, etc.) using proprietary pods. The main control board printed circuit board assemblies (PCBAs), program, configure, and these main control board PCBAs in the United States. |
| Reason: Almost all or the overwhelming majority of the components and subassemblies, including the PCBAs (other than the main board PCBAs) are manufactured in China. Any non-Chinese-origin components used in the manufacture of the ColdSnap Systems including the main board PCBAs, lose their identity and are substantially transformed when they are combined with the other Chinese-origin components. |
| Ruling Date: Aug. 22, 2025 |
N352073: The country of origin of brake shoes
| Origin: China |
| Item: The articles under consideration are “bare steel” brake shoes, which are used in heavy duty trucks. Each brake shoe lacks the friction material that is typically attached to the shoe using rivets. The brake shoes consist of a table and two pieces of webs, which are imported into the Philippines from China. In the Philippines, the table and webs are welded together, and the completed assembly is heat treated and painted. |
| Reason: All of the components are sourced from China. They do not lose their individual identities when they are welded together, heat-treated, and cleaned in the Philippines. |
| Ruling Date: Aug. 22, 2025 |
N352129: The tariff classification of pillow and pillowcase samples from China
| HTS: 9811.00.60, free, “any sample (except samples covered by heading 9811.00.20 or 9811.00.40), valued not over $1 each, or marked, torn, perforated or otherwise treated so that it is unsuitable for sale or for use otherwise than as a sample, to be used in the United States only for soliciting orders for products of foreign countries.” |
| Item: Samples of pillows and pillowcases clearly marked with the word “SAMPLE” using a permanent marker with indelible ink. |
| Reason: N/A |
| Ruling Date: Aug. 22, 2025 |
N352134: The tariff classification of samples of wearing apparel under heading 9811.00.60
| HTS: 9811.00.60, free, “any sample (except samples covered by heading 9811.00.20 or 9811.00.40), valued not over $1 each, or marked, torn, perforated or otherwise treated so that it is unsuitable for sale or for use otherwise than as a sample, to be used in the United States only for soliciting orders for products of foreign countries.” |
| Item: Jackets and trousers imported with the intent of soliciting orders for products of foreign countries and that the word “sample” is written by the manufacturer with a permanent marker on both garments. |
| Reason: N/A |
| Ruling Date: Aug. 22, 2025 |
N352190: The country of origin of a battery charging system
| Origin: Korea |
| Item: The merchandise at issue with this request is described as an Electric Vehicle Battery Charger System, which is composed of two Dispenser modules and a Power Cabinet. The two dispenser units are comprised of an enclosure, within which is the electrical control apparatus, a power supply, and a cooling system. The power modules, which are incorporated into the power cabinet are manufactured in China and imported into Korea. In Korea, seven PCBAs are manufactured via surface mount technology (SMT) that will be incorporated into the dispenser unit. |
| Reason: The manufacture of the critical control printed circuit board assemblies (PCBAs), via SMT, creates the elements that impart the character of the finished device. Though the power modules manufactured in China are important components, the PCBAs along with the advanced assembly process establish the intended functionality of the device. As such, the Electric Vehicle Battery Charger System, when imported together, is considered a product of Korea. |
| Ruling Date: Aug. 22, 2025 |
N352195: The tariff classification of a costume from China and Vietnam
| HTS: 9505.90.6000, 9903.01.24; 9903.01.25; 9903.02.69, free + 20% + 10% OR + 20%, “Festive, carnival or other entertainment articles, including magic tricks, and practical joke articles; parts and accessories thereof: Other: Other.” |
| Item: A child-size costume identified as Dragon Rider, which consists of a pullover long-sleeved upper body garment which you refer to as a tunic, a cape, mask, boot tops, medallion and chest straps with belt, and features a neck and deep back opening with large, visible, loose overlock stitching. The deep back opening is closed with a single small tab of hook and loop fastener. |
| Reason: The flimsy man-made knitted textile upper body garment provides the essential character of the set. |
| Ruling Date: Aug. 22, 2025 |
N352202: The tariff classification of a costume from China and Vietnam
| HTS: 9505.90.6000, 9903.01.24; 9903.01.25; 9903.02.69, free + 20% + 10% OR + 20%, “Festive, carnival or other entertainment articles, including magic tricks, and practical joke articles; parts and accessories thereof: Other: Other.” |
| Item: An adult-size costume identified as Twisted Clown, which consist of a long-sleeved pullover dress, separate collar, petti skirt, socks and mini hat, and has a neck that is folded once and stitched with a single line of long loose straight stitching. The long sleeves feature raw, jagged cut edges and narrow, exposed elastic stitched on with a single line of long, loose straight stitching. Although the front of the dress is pieced and has some gathering, the dress is not well made. |
| Reason: The flimsy man-made knitted textile dress provides the essential character of the set. |
| Ruling Date: Aug. 22, 2025 |
N352223: The country of origin of a liquid crystal lighting device
| Origin: Philippines |
| Item: The device is composed of multiple liquid crystal panels laid over the top of each other with printed circuit connectors on two sides. In use, the device is installed within an LED light source, such as an overhead lamp. The manufacturing process begins in Japan with the creation of a liquid crystal panel by depositing a thin film of crystals onto a glass substrate. This panel is then sent to the Philippines where it is cut to the necessary size, and the flexible printed circuits (FPC) are attached. |
| Reason: The process performed in the Philippines imparts the optical properties of the device. As the device functions by interacting and altering the light which passes through it, this process creates the critical component of the device. Though the driver board is an important component, it only adds to the optical function and would not be considered the character of the finished article. |
| Ruling Date: Aug. 22, 2025 |
N352306: The country of origin of two models of battery chargers
| Origin: Malaysia |
| Item: Two models of battery chargers intended for use with all types of lead-acid 12-volt batteries, i.e. conventional vehicle batteries. |
| Reason: The assembly of the printed circuit board assembly (PCBA) in Malaysia by surface mounting and through-hole insertion soldering of various electronic components onto a bare printed circuit board results in a substantial transformation of the components to produce PCBAs of Malaysian origin. Furthermore, the PCBA, which functions to convert the input voltage and control the charging of the attached battery, establishes the character of the electrical charging function. The assembly processes done in China, which includes inserting, attaching, gluing, etc., are not complex and are considered basic assembly. |
| Ruling Date: Aug. 22, 2025 |
N352394: The tariff classification of a cordless robotic pool cleaner from China
| HTS: 8421.21.0000, 9903.01.24; 9903.01.25; 9903.88.01, free + 20% + 10% + 25%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: For filtering or purifying water.” |
| Item: The item under consideration is the SPINO E1, which is a cordless robotic pool cleaner designed to automatically remove debris and dirt from swimming pools. The device features a built-in, removable, and reusable filter basket. |
| Reason: N/A |
| Ruling Date: Aug. 22, 2025 |