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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N352763: The Country of origin, and eligibility of the United States-Mexico Canada Agreement (USMCA), of LED tube lights from Mexico
| HTS: 8539.52.0051, 2%, “Electrical filament or discharge lamps, including sealed beam lamp units and ultraviolet or infrared lamps; arc lamps; light-emitting diode (LED) light sources; parts thereof: Light-emitting diode (LED) light sources: Light-emitting diode (LED) lamps: Straight linear tubes or U-shaped tubes.” |
| Origin: Mexico |
| USMCA Eligibility: Yes |
| Item: The merchandise under consideration is identified as the Obert’s LED tube lights, which are 15-Watt linear lamps designed to replace traditional fluorescent tube lights. The LED tube lights will be produced in Mexico, where the factory will produce certain components, and assemble them with the Chinese-originating components to fabricate the finished LED tube lights. |
| Reason: The manufacturing process in Mexico, including the SMT operation along with other assembly operations, is complex and meaningful as to result in a substantial transformation, such that these components lose their individual identities and become an integral part of a new article, possessing a new name, character, and use. In addition, the LED light source, which is the critical part of the finished LED tube lights, is made in Mexico. It imports the character of the finished products. Therefore, the country of origin of LED tube lights is Mexico. |
| Ruling Date: Sept. 5, 2025 |
N352862: The tariff classification of a Halloween decoration from China
| HTS: 9505.90.6000, 9903.01.24; 9903.01.25, free + 20% + 10%, “Festive, carnival or other entertainment articles, including magic tricks, and practical joke articles; parts and accessories thereof: Other: Other.” |
| Item: An item identified as Halloween Skeleton Animated Decor, which consists of a battery-powered plastic skeleton lying prone on a flat surface. When any weighted object is placed on the center portion, the skeleton is activated. The head rises, the mouth opens and arms and legs rise up. The skeleton returns to the prone position when the weighted object is lifted off of it. |
| Reason: N/A |
| Ruling Date: Sept. 5, 2025 |
N353157: The tariff classification of a hematology slide stainer from Germany
| HTS: 8479.89.9599, 9903.02.20, 2.5% + 12.5%, “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other: Other.” |
| Item: The Hematek® 3000 System is a self-contained, bench-top hematology slide stainer. This machine is used to stain slides to prepare them for analysis and digital microscopy. |
| Reason: N/A |
| Ruling Date: Sept. 5, 2025 |
N352003: The country of origin of an oven spark plug assembly
| Origin: Thailand or China |
| Item: The product under consideration is described as a “spark plug” and will be used with a gas range to ignite the burner. In the first manufacturing scenario, all the components are sourced from Thailand except the ceramic insulator, which will be of Chinese origin. These components will be assembled in Thailand. In the second configuration, all the components are sourced from China except the ceramic insulator, which will be of Thai origin. These components will be assembled in Thailand. |
| Reason: In the first scenario, since the majority of the components are from Thailand and are assembled into the final product in Thailand, the country of origin of the spark plug assembly will be Thailand. In the second scenario, since the majority of the components are from China, the country of origin of the spark plug assembly is China. |
| Ruling Date: Sept. 4, 2025 |
N352231: The country of origin of Razor Clams
| Origin: Ireland |
| Item: The subject merchandise is Canned Razor Clams in Olive Oil. The merchandise consists of live clams harvested in Ireland. The clams are shipped live to Spain where the clams are cooked in their shells, after which the meat is manually extracted, placed into cans, and covered in olive oil of Spanish origin. |
| Reason: Although the clams are subjected to significant processing in Spain (cooking, shelling, preservation in an oil medium and canning), these operations do not constitute a substantial transformation. |
| Ruling Date: Sept. 4, 2025 |
N352317: The tariff classification of housings for 5 electric motors from Vietnam
| HTS: 8503.00.9520, 9903.81.91, 9903.02.69, 3% + 50% + 20%, “Parts suitable for use solely or principally with the machines of heading 8501 or 8502: Other: Parts of motors.” |
| Item: Five electric motor housings made of low carbon steel and used to house AC or DC motors. |
| Reason: N/A |
| Ruling Date: Sept. 4, 2025 |
N352361: The tariff classification of a flexible laminated aluminum foil-plastic product from France
| HTS: 7607.20.1000, 9903.85.02; 9903.01.33, 3.7% + 50%, “aluminum foil (whether or not printed, or backed with paper, paperboard, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2 mm: backed: covered or decorated with a character, design, fancy effect or pattern.” |
| Item: The item under consideration is identified as a flexible, laminated plastic product (F12-011) that is used in the manufacture of unit-dose cosmetic sampling. It is imported in roll stock format, printed with customer-specific artwork and ready to be converted into finished samples with the appropriate cosmetic products added. |
| Reason: N/A |
| Ruling Date: Sept. 4, 2025 |
N352382: The tariff classification and country of origin determination for tents and mesh insert; 19 CFR 102.21 (c)(2); 19 CFR 102.21(c)(5)
| HTS: (Tents) 6306.22, 9903.01.24; 9903.01.25; 9903.88.15, free + 20% + 10% + 7.5%, “Tarpaulins, awnings and sunblinds; tents (including temporary canopies and similar articles); sails for boats, sailboards or landcraft; camping goods: Tents (including temporary canopies and similar articles): Of synthetic fibers.” (Sage Canyon Mesh Insert) 6307.90.9891, 9903.02.69, 7% + 20%, “Other made up articles, including dress pattern: Other: Other: Other: Other: Other.” |
| Origin: China and Vietnam |
| Item: Four tents and a mesh insert. |
| Reason: It is the tents, and the mesh insert that are the main components that are necessary when the user is camping outdoors. The tent is the component that provides shelter. The mesh insert when used with the Sage Canyon Shelter provides bug protection. The backpack and stuff sack are specially designed to hold, store, and transport the tent and mesh insert. Therefore, in accordance with GRI 3(b), the tent and mesh insert impart the essential character and thus determines the classification. |
| Ruling Date: Sept. 4, 2025 |
N352398: The tariff classification of a Solar Tower from Belgium
| HTS: 8501.72.2000, 9903.02.20, 2% + 13%, "Electric motors and generators…: Photovoltaic DC generators: Of an output exceeding 50 W: Of an output exceeding 750 W but not exceeding 75 kW." |
| Item: The merchandise under consideration is referred to as the “Stalico Solar Tower.” This mobile unit allows these various components to be stationed in remote areas and raised to various heights via the telescoping mast. |
| Reason: N/A |
| Ruling Date: Sept. 4, 2025 |
N352410: The tariff classification of non-penetrating roof mounts from Canada
| HTS: 7326.90.8688, 9903.81.90; 9903.01.26, 2.9% + 50%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The items under consideration are three models of non-penetrating roof mounts (NPRMs) used to mount communication equipment such as antennas, radios, repeaters, and video surveillance equipment onto flat roofs. The NPRMs consist of rigid, galvanized steel frames designed to be weighed down with cinder blocks or patio stones for stability. |
| Reason: N/A |
| Ruling Date: Sept. 4, 2025 |