Newly Released CBP HQ Rulings Dec. 30
The Customs Rulings Online Search System (CROSS) was updated on Dec. 30 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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H343451: Application for Further Review of Protest No 460124137945; Classification of AquaHT water heater module
| Ruling: The AquaHT is classified under heading 8516, specifically subheading 8516.10.00, which provides, in relevant part, for: “Electric instantaneous or storage water heaters and immersion heaters…: Electric instantaneous or storage water heaters and immersion heaters….” |
| Issue: What is the proper classification for the AquaHT? |
| Item: Fresenius Medical Care's AquaHT water heater module, which can be used for multiple purposes, including heat disinfection of the reverse osmosis system with membranes; heat disinfection of the dialysis water ring main; and as a supply of hot dialysis water to the dialysis devices and their connecting lines while heat disinfection of the dialysis water ring main is in progress. |
| Reason: The AquaHT is designed to heat water by operation of multiple heating elements that are powered by electricity. The water is later drawn by the AquaA and circulated through a network of hoses, loops and other conduits to disinfect the AquaA. Based on the function of the AquaHT as an “electric water heater,” it is properly classified in heading 8516.10.00. |
| Ruling Date: Oct. 28, 2025 |
H345634: Request for Further Review of Protest No. 1803-25-102577; Tariff Classification of Certain Hinges
| Ruling: The subject aluminum hinges are classified in heading 8302, specifically in subheading 8302.10.3000, HTSUSA, which provides for “Base metal mountings, fittings and similar articles . . . : Hinges, and parts thereof: Of iron or steel, of aluminum or of zinc: Designed for motor vehicles.” |
| Issue: Whether the TALH series hinges are properly classified in subheading 8302.10.30 as hinges designed for motor vehicles or in subheading 8302.10.60 as “other” hinges. |
| Item: Jammy Inc.'s door hinges for recreational vehicles |
| Reason: CBP finds TALH series hinges are designed for use in motor vehicles. The Z-shaped hinges enable the doors to be concealed when opened completely for improved security and improved appearance. The hinge design also allows the doors to accommodate the installation of a weather seal around the perimeter of the door. Furthermore, unlike other hinges that open and close onto one another, the three-leaf and five-leaf design of the TALH hinges do not oppose each other, allowing for a closer door fit. Finally, the design allows the door to move up and down on its frame by a small amount which prevents the flexing of more rigid hinges that could damage the door or doorframe components. |
| Ruling Date: Dec. 16, 2025 |
H350894: U.S. Government Procurement; Title III, Trade Agreements Act of 1979 (19 U.S.C. § 2511); Subpart B, Part 177, CBP Regulations; Country of Origin of Lumens Camera
| Country of Origin: Based on the information provided, for purposes of U.S. government procurement, the Lumens PTZ Camera is a product of Taiwan. |
| Issue: What is the country of origin of the Lumens Camera for the purposes of U.S. government procurement? |
| Item: Pan Tilt Zoom (PTZ) Lumens VC-TR60A Camera, designed for video conferencing in office environments |
| Reason: In rulings concerning the country of origin of a device containing multiple printed circuit board assemblies (PCBAs), CBP has examined the function of the PCBAs contained in the device to determine the origin of the device. The zoom sensor board, panoramic sensor board, and main board are essential to the character of the finished camera, as they are responsible for capturing and converting images. These boards enable the camera to function as intended. These boards are produced in Taiwan. Additionally, the zoom lens assembly, which is the longest and most complex assembly process, takes place in Taiwan. |
| Ruling Date: Dec. 19, 2025 |