Newly Released CBP HQ Rulings Dec. 19
The Customs Rulings Online Search System (CROSS) was updated on Dec. 19 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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H335210: Application for Further Review of Protest No. 4601-23-135690; Tariff classification of the “VOX Reader”
| Ruling: By application of General Rules of Interpretation 1 and 6, the VOX Reader is classified in heading 8519, specifically in subheading 8519.81.41, which provides for “Sound recording or reproducing apparatus: Other apparatus: Using magnetic, optical, or semiconductor media: Other.” |
| Issue: Is the VOX reader classifiable in subheading 8519.81.30 as an apparatus that only reproduces sound, or in subheading 8519.81.41 as other sound recording or reproducing apparatus? |
| Item: Library Ideas' VOX Reader, a device that is used with Protestant’s “VOX Books,” which the Protestant describes as audiobooks that reside within print books to create a read-along experience. |
| Reason: In its imported condition, the “[t]he VOX Reader is imported into the U.S. without a recording on it or with a recording that was added solely to test the unit.” Moreover, after importation into the U.S., the Protestant substantiated that it records an audiobook onto VOX Reader, which is then permanently attached to the print book corresponding with the audiobook content. That the protestant records an audiobook onto the VOX Reader after importation demonstrates that in its condition as imported, the VOX Reader is capable of both recording and reproducing sound. |
| Ruling Date: Oct. 14, 2025 |
H338600: Application for Further Review of Protest No 530123109507; Classification of removable cart shelves
| Ruling: By application of GRIs 1 and 6, the removable cart shelves are classified under subheading 9403.99.90, which provides for “Other furniture and parts thereof: Parts: Other: Other: Other.” |
| Issue: Are the removable cart shelves classified under heading 8716 or heading 9403? |
| Item: Vista Retail Solutions' removable cart shelves, used exclusively with mobile commercial carts for temporary store displays. |
| Reason: The cart shelves are used exclusively with mobile carts for temporary store displays. The mobile carts are not principally designed for the transport of goods or persons. They are used for storage and retail displays for food, nursery and other household consumer products inside and outside of a store. As a result, any “transport function” of the carts is subsidiary to their display and storage function. In view of the foregoing, the cart shelves are not suitable for use solely or principally with an article of heading 8716 and are not classifiable in heading 8716. Rather, the subject removable cart shelves, which are solely designed for use with commercial carts and for mobile metal store display carts, fall within the definition of furniture," and are classified in heading 9403. On their own, however, the removable cart shelves are not designed for placement on the floor or ground and do not provide utilitarian value in and of themselves. Consequently, the removable cart shelves cannot be described as other metal furniture of subheading 9403.20. The subject removable shelves are principally designed to be used with carts for storage and display of articles in and outside of a store. Once installed, they enable the cart to function as a display for food, nursery or other household consumer products. Therefore, the removable shelves are parts of a cart, and they are furniture within the meaning of heading 9403. |
| Ruling Date: Oct. 15, 2025 |
H352465: County of Origin; United States-Colombia Trade Promotion Agreement (CTPA); Regional Value Content; Lifthauler Trailers
| Ruling: The country of origin of the subject Lifthauler Trailers for purposes of marking and trade remedies will be Colombia. The subject Lifthauler Trailers qualify for preferential tariff treatment under the United States-Colombia Trade Promotion Agreement (CTPA). |
| Issue: Whether the subject Lifthauler Trailers qualify for preferential tariff treatment under the CTPA; and what is the country of origin of the subject Lifthauler Trailers for purposes of marking and trade remedies. |
| Item: Combo Lifthauler Trailers manufactured in Colombia. The 45-foot Lifthauler Trailers have an air-ride suspension designed for commercial transportation. |
| Reason: The value of materials (VOM) is calculated by adding up the value of all components of U.S. and Colombian origin plus labor, overhead, engineering & design, vendor profit and vendor Colombian tax payments. The regional value content (RVC) under the build-up method is ($17,145.09 / $29,167.67) x 100, which is 58.8%. Because the RVC under the build-up method is greater than 35%, the applicable rule of origin under GN 34(o), Chapter 87, Rule 11(B)(1) is satisfied. As for country of origin, while certain foreign components, including trailer axles, steel plates and wheels, fasteners, and suspension components, are integrated into the final assembly, many of the most important subassemblies, including the air-ride suspension modules, electrical harnesses and electrical system, kingpin system, and floor decking components, are assembled in Colombia through complex manufacturing operations. Additionally, laser cutting, chamfering, CNC bending, and hole routing of steel components that are integral to the trailer chassis frame, and fabrication and welding of the structural trailer chassis frame and load-bearing platform, are complex operations performed in Colombia. |
| Ruling Date: Dec. 8, 2025 |
H346979: Country of Origin of EcoSyntane; Substantial Transformation; Section 301; IEEPA
| Country of Origin: The country of origin of EcoSyntane will be U.S. Virgin Islands for purposes of Section 301 and IEEPA duties. |
| Issue: What is the country of origin of EcoSyntane for purposes of applying trade remedies under Section 301 and the International Economic Emergency Powers Act? |
| Item: EcoSyntane, a company-branded product used in spark-ignition internal combustion engines |
| Reason: EcoSyntane is specifically formulated to comply with key specifications and is suitable for use in automobiles. Further, without the essential characteristics imparted by the primary input components and intermediate input components to the final product, EcoSyntane could not be used as intended. Moreover, all of the primary input components and intermediate input components do not have the same use as the final product, as they do not meet the same key specifications that are met by EcoSyntane for use in automobiles. Accordingly, CBP finds that the manufacturing operations to produce EcoSyntane also result in a change in use of the primary input components and intermediate input components. Therefore, CBP finds that a substantial transformation results from manufacturing operations in USVI to produce EcoSyntane from the primary input components and intermediate input components. |
| Ruling Date: Dec. 8, 2025 |