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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.

N352221: The tariff classification of a desktop ticket dispenser from China

HTS: 3926.90.9989, 9903.01.24; 9903.01.25; 9903.88.15, 5.3% + 20% + 10% + 7.5%, “[o]ther articles of plastics and articles of other materials of headings 3901 to 3914: [o]ther: [o]ther: [o]ther.”
Item: The product under consideration is described as a desktop ticket dispenser, which is intended to serve as a novelty office item and includes the plastic dispenser with stand, a roll of 99 paper tickets, and a digital board that shows the number being served.
Reason: It is the plastic ticket dispenser which imparts the essential character.
Ruling Date: Aug. 27, 2025

N352325: The tariff classification of solar cells from Germany

HTS: 8541.42.0080, 9903.02.20, free + 15%, “Semiconductor devices (for example, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panel…: Photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED): Photovoltaic cells not assembled in modules or made up into panels: Other.”
Item: The items concerned are Metal Wrap Through (MWT) solar cells which are designed for space-based applications. The MWT cells are high efficiency triple junction Gallium Arsenide “micro-cells.” The semiconductor material used to manufacture these solar cells consists of indium gallium phosphide (InGaP), indium gallium arsenide (InGaAs) and germanium (Ge), they do not utilize crystallized silicon. The solar cells are manufactured in Germany.
Reason: Since the Metal Wrap Through solar cells are not crystal silicon photovoltaic cells, they do not fit the definition of the covered products found in legal note, Note 18, and as such are not subject to the additional duties imposed by the Solar 201 safeguards.
Ruling Date: Aug. 27, 2025

N352484: The country of origin of patch cord assemblies

Origin: U.S.
Item: The merchandise under consideration is described as five models of a fiber optic patch cord assembly, which are further described as fiber optic cables that consist of a fiber optic core, which consists of 2 or 12 optical fibers depending on the model number. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the United States.
Reason: The fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce as their end use is predetermined and they perform the primary function of transmitting the data signals.
Ruling Date: Aug. 27, 2025

N352529: The country of origin of patch cord assemblies

Origin: U.S.
Item: The merchandise under consideration is described as five models of a fiber optic patch cord assembly, which are further described as fiber optic cables that consist of a fiber optic core, which consists of 6 or 12 optical fibers depending on the model number. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the United States.
Reason: The fiber cores manufactured in the United States impart the character of the finished cables. Further, the assembly process performed in China, including the addition of the covering and connectors, does not substantially transform the cores into new and different articles of commerce as their end use is predetermined and they perform the primary function of transmitting the data signals.
Ruling Date: Aug. 27, 2025

N352655: The country of origin of a digital coin counting bank

Origin: Vietnam
Item: The digital coin bank automatically tracks or counts the coin deposits and displays the total on an analog display. It features a large capacity coin jar with removable lid for easy access to the deposited coins. The PCBAs are fabricated through the surface mount technology (SMT) operation in Vietnam.
Reason: A significant number of the parts or components are made in Vietnam. The manufacturing process, including the SMT process and plastic injection molding along with other assembly operations, is complex and meaningful as to result in a substantial transformation.
Ruling Date: Aug. 27, 2025

N351725: The tariff classification and country of origin of cellular polystyrene sheets and shiplap boards

HTS: 3921.11.0000, 9903.01.10, 5.3% + 35%, “other plates, sheets, film, foil and strip, of plastics: cellular: of polymers of styrene.”
Origin: Canada
Item: The product under consideration is referred to as ECO Carbon Foam. The product is produced from a mixture of virgin and recycled polystyrene, talc, flame retardant and colorant. It is intended for use as a foam insulation. United States and Canadian origin Virgin and recycled polystyrene, talc, and colorant and Israeli origin flame retardant are sent to the Canadian manufacturing facility.
Reason: The foreign materials used in the production of these sheets meet the applicable change in tariff classification. Therefore, the country of origin of these cellular polystyrene sheets and shiplap boards will be Canada.
Ruling Date: Aug. 26, 2025

N351858: The tariff classification of Azelastine Hydrochloride (HCL) Nasal Spray in dosage form from India

HTS: 3004.90.9280, 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 eyes, ears or respiratory system: Other: Antihistamines.”
Item: Azelastine Hydrochloride Nasal Spray, imported in 30 mL, is an antihistamine. It is indicated for the treatment of the symptoms of seasonal allergic rhinitis in adults and pediatric patients 5 years of age and older, and for the treatment of the symptoms of vasomotor rhinitis in adults and adolescent patients 12 years of age and older.
Reason: N/A
Ruling Date: Aug. 26, 2025

N351952: The tariff classification of storyboard and clings from China

HTS: 4911.91.4040, 9903.01.22; 9903.01.31; 9903.88.15, free + 7.5%, “Other printed matter, including printed pictures and photographs: Other: Pictures, designs and photographs: Printed not over 20 years at time of importation: Other: Other: Other.”
Item: The item under consideration is Item #68761 Monster Storybook and Cling Set, a printed storyboard and printed plastic clings. The storyboard folds in half and is printed on one side with a mountain and river scene and on the other with a wooded scene. The clings are printed with “Monster Summer Camp” images, including monsters engaged in summer and camping activities, woodland creatures, and camping motifs, like tents. The clings are adhesive-free and can be positioned and re-positioned on the storyboard. The storyboard and clings are digitally printed.
Reason: N/A
Ruling Date: Aug. 26, 2025

N351962: The country of origin of a laser measurement tool

Origin: Vietnam
Item: The item under consideration is described as a laser measurement tool, which is a battery-operated electronic device used to provide various measurement readings. The laser measurement tool mainly consists of a Vietnamese engine Printed Circuit Board Assembly (PCBA) and charging PCBA, and a Taiwanese laser diode.
Reason: The creation of the Vietnamese engine and charging PCBAs provide the essence of the finished laser measurement tool, including the measurement capability. The additional assembly process performed in China is not complex and does not transform the PCBAs into a new article.
Ruling Date: Aug. 26, 2025

N352027: The tariff classification of jewelry findings from China

HTS: 7117.19.9000, 11% + 20% + 10%, “Imitation jewelry: Of base metal, whether or not plated with precious metal: Other: Other: Other.”
Item: Three types of findings composed of brass: eye pins, head pins, and jump rings. They are component parts used in the manufacture of jewelry such as necklaces and earrings.
Reason: N/A
Ruling Date: Aug. 26, 2025