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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N352075: The tariff classification and country of origin of furniture components of metal from China
| HTS: 9403.99.9040, 9903.01.24; 9903.81.91; 9903.01.25; 9903.88.03, free + 20% + 10% + 50%, “Other furniture and parts thereof: Parts: Other: Other: Other: Other: Of metal: Parts for steel racks of statistical reporting number 9403.20.0082.” |
| Origin: China |
| Item: The merchandise is a hot rolled rectangle and square steel metal frame for a storage rack. |
| Reason: The hot rolled Chinese steel sheet metal loses its identity during manufacture and undergo a substantial transformation in China to become both assembled and unassembled metal shelf components, thereby, taking on new names, characters, and uses. |
| Ruling Date: Aug. 28, 2025 |
N352083: The tariff classification and eligibility under the United States-Mexico-Canada Agreement (USMCA) of Chocolate Blends from Mexico
| HTS: 1806.20.9900, 8.5%, “Chocolate and other food preparations containing cocoa...Other preparations in blocks, slabs or bars, weighing more than 2 kg or in liquid, paste, powder, granular or other bulk form in containers or immediate packings, of a content exceeding 2 kg…...other...other...other…other…other.” |
| USMCA Eligibility: Yes |
| Item: Four Chocolate Blends, containing cocoa butter and chocolate liquor that is from various countries. All of the ingredients are sent to Mexico where they are blended into the finished chocolate blend. |
| Reason: N/A |
| Ruling Date: Aug. 28, 2025 |
N352140: The tariff classification of metal cans and can ends (lids and bases) from Japan
| HTS: 7310.21.0075, 9903.81.90; 9903.02.30, free + 50% + 15%, “Tanks, casks, drums, cans, boxes and similar containers, for any material (other than compressed or liquefied gas), of iron or steel, of a capacity not exceeding 300 liters, whether or not lined or heat insulated, but not fitted with mechanical or thermal equipment: Of a capacity of less than 50 liters: Cans which are to be closed by soldering or crimping: Other.” |
| Item: Tin plate steel sheet containers used for the commercial conveyance, packaging, storage, and transport of beer beverages. |
| Reason: N/A |
| Ruling Date: Aug. 28, 2025 |
N352141: The tariff classification of paperboard picture frame kit from China
| HTS: 4823.90.6700, 9903.01.24; 9903.01.25; 9903.88.03, free + 20% + 10% + 25%, “Other paper, paperboard, cellulose wadding and webs of cellulose fibers, cut to size or shape; other articles of paper pulp, paper, paperboard, cellulose wadding or webs of cellulose fibers: Other: Other: Other: Of coated paper or paperboard: Other.” |
| Item: The product under consideration is a paperboard picture frame kit. The kit consists of die-cut paperboard circles to which die-cut paperboard petals are affixed. The paperboard pieces each have an adhesive piece on the back for assembly with the other paperboard pieces. The kit comes packaged together for retail sale and is marketed as a child’s craft activity. |
| Reason: The unassembled paperboard picture frame imparts the essential character of the set. |
| Ruling Date: Aug. 28, 2025 |
N352155: The tariff classification and country of origin of inner and outer tie rods
| HTS: 8708.94.7550, 9903.94.05; 9903.01.33, 2.5% + 25% + 19%, “Parts and accessories of the motor vehicles of heading 8701 to 8705: Other parts and accessories: Steering wheels, steering columns and steering boxes; parts thereof: Parts: For other vehicles: Other: Other.” |
| Origin: Malaysia |
| Item: The articles under consideration are Inner Tie Rods and Outer Tie Rods, which are used in passenger vehicles. The inner tie rods are parts of the automobile steering mechanism, which directly affect the stability of the automobile handling, safety of operation and service life of the tires. The outer tie rods are often used in conjunction with inner tie rods, with one end connected to the tire. The housing and the ball pin of the inner tie rods are sourced from Malaysia, while the clip, ball socket, nut, gaskets, brackets, and cable ties are sourced from China and imported into Malaysia to be assembled to create the complete inner tie rods. The outer tie rods are also assembled in Malaysia from the boot, housing, and ball pin from Malaysia, and the nut, bolt, spiral ring clips, ball socket, backing plate, glib, and gasket from China. |
| Reason: The assembly process described for the inner and outer tie rods does not appear to be complex enough to render a substantial transformation. None of the components transform into a new article after being turned, laser marked, greased, pressed into one another, tested, and packaged in Malaysia. Thus, it is the country of origin of the major components of each tie rod assembly which determines the origin. The housings and ball pins in both assemblies impart the character of the inner and outer tie rods. |
| Ruling Date: Aug. 28, 2025 |
N352170: The tariff classification of glucose monitor patches from China and a glucose monitor case from Vietnam
| HTS: (Patches) 9027.90.5695, 9903.01.24; 9903.01.25, 9817.00.96, free, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Microtomes; parts and accessories: Parts and accessories: Of electrical instruments and apparatus: Other: Of instruments and apparatus of subheading 9027.20, 9027.30, 9027.50, 9027.81 or 9027.89: Other.” (Case) 4202.92.0807, 9903.02.69, 9817.00.96, 7%, “Trunks, suitcases, vanity cases, attache cases, briefcases, school satchels, spectacle cases, binocular cases, camera cases, musical instrument cases, gun cases, holsters and similar containers; traveling bags, insulated food or beverage bags, toiletry bags, knapsacks and backpacks, handbags, shopping bags, wallets, purses, map cases, cigarette cases, tobacco pouches, tool bags, sports bags, bottle cases, jewelry boxes, powder cases, cutlery cases and similar containers, of leather or of composition leather, of sheeting of plastics, of textile materials, of vulcanized fiber or of paperboard, or wholly or mainly covered with such materials or with paper: Other: With outer surface of sheeting of plastics or of textile materials: Insulated food or beverage bags: With outer surface of textile materials: Other: Of man-made fibers.” |
| Item: The first item under consideration is the WALG Continuous Glucose Monitoring Patch, which is a group of 20 adhesive patches designed specifically to secure the sensor of a CGM system in place on the skin. CGM devices are used by individuals with diabetes to continuously monitor their blood glucose levels. The second item under consideration is described as the WALG Insulin Cooling Case, which is a cooling case designed to keep insulin pens or vials cool and safe while traveling or on the go. |
| Reason: N/A |
| Ruling Date: Aug. 28, 2025 |
N352218: The tariff classification of toilet paper from Turkey
| HTS: 4818.10.0000, 9903.02.64, free + 15%, “Toilet paper and similar paper, cellulose wadding or webs of cellulose fibers, of a kind used for household or sanitary purposes, in rolls of a width not exceeding 36 cm, or cut to size or shape; handkerchiefs, cleansing tissues, towels, tablecloths, table napkins, bed sheets and similar household, sanitary or hospital articles, articles of apparel and clothing accessories, of paper pulp, paper, cellulose wadding or webs of cellulose fibers: Toilet paper.” |
| Item: The product under consideration is Selpak Comfort Toilet Paper, packaged as 12 rolls per pack, with 150 sheets per roll. The toilet paper made with 100% virgin pulp, embossed, three-ply, perforated, and rolled on a cardboard core. |
| Reason: N/A |
| Ruling Date: Aug. 28, 2025 |
N352224: The tariff classification of an ethylene propylene diene monomer (EPDM) rubber gasket assembly from South Korea
| HTS: 4016.93.1050, 9903.02.56, 2.5% + 15%, “... other articles of vulcanized rubber other than hard rubber: other: gaskets, washers and other seals: of a kind used in the automotive goods of chapter 87: other.” |
| Item: A gasket assembly seated at the outermost edge of the vehicle chassis between the upper and lower cases of the electric vehicle battery. It serves to seal the interior against foreign substances and moisture that may enter from outside the battery providing an air and water tight seal. It is composed ethylene propylene diene monomer (EPDM) rubber that is perforated at regular intervals with small steel rings in the holes for connection. |
| Reason: The essential character is imparted by the EPDM rubber component. |
| Ruling Date: Aug. 28, 2025 |
N352230: The country of origin of an ultrasonic sensor module
| Origin: China |
| Item: The item under consideration is described as an ultrasonic sensor module, which is a functional component in the automatic water filling system of smart refrigerators. It consists of a front plastic bracket and an ultrasonic sensor module, assembled as a single integrated unit. The manufacturing process occurs in Malaysia with components from Malaysia and China. |
| Reason: The assembly of the ultrasonic sensor module in Malaysia does not substantially transform the individual Chinese components into a new article with a name, character, and use. The components undergo simple assembly in Malaysia and they do not have a different purpose when they leave China compared to the final product when it leaves Malaysia. The addition of the Malaysian plastic bracket holds the ultrasonic sensor in place, but it is still the ultrasonic sensor performing the essential function of the finished article. |
| Ruling Date: Aug. 28, 2025 |
N352250: The tariff classification and country of origin for metallized, coated polyethylene terephthalate (PET) film
| HTS: 3920.62.0050, 9903.01.24, 9903.01.25, 9903.88.02, 4.2% + 20% + 10% + 25%, “... other plates, sheets, film, foil and strip, of plastics, noncellular and not reinforced, laminated, supported or similarly combined with other materials: of poly(ethylene terephthalate): metallized PET film: other.” |
| Origin: China |
| Item: Metallized polyethylene terephthalate (PET) sheets with acrylic release and scuff-resistant coating. In China polyethylene terephthalate (PET) base film is manufactured via extrusion, and an acrylic release coating is applied. The coated PET film is shipped to Canada. In Canada the film undergoes metallization with aluminum by a vacuum metallization process. This is followed by the application of additional performance enhancing coatings. The film is then slit into various widths based on customer specifications. |
| Reason: The metallizing and coating the PET film in Canada does not result in a substantial transformation. |
| Ruling Date: Aug. 28, 2025 |