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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N353164: The tariff classification of compression limiters from Germany
| HTS: 7326.90.8688, 9903.81.90; 9903.01.33, 2.9% + 50%, “Other articles of iron or steel: Other: Other: Other: Other: Other.” |
| Item: The items under consideration are four models of “wrapped metal” steel compression limiters. When plastic vehicle components are fastened to other objects, the normal forces of screws and bolts in a tightened state can exceed the permissible surface pressure of plastic, causing damage. Steel compression limiters are used to prevent such damage by providing structural reinforcement around the cylindrical opening. |
| Reason: N/A |
| Ruling Date: Sept. 9, 2025 |
N352114: The tariff classification and eligibility under the Nairobi Protocol of metal furniture from China
| HTS: 9403.20.0050, 9817.00.96, free, “Other furniture and parts thereof: Other Metal furniture: Household: Other: Other.” |
| Item: The “StrongArm Bedside Rail Support System” is a steel tube bed rail anchor, grab bar, and step platform coated in enamel that is designed to facilitate the user’s entry and exit from a bed. The bedrail anchor, grab bar, and step platform are adapted one to the other and form a unitary whole. |
| Reason: N/A |
| Ruling Date: Sept. 8, 2025 |
N352216: The country of origin of Wet Wipes
| Origin: South Korea |
| Item: Cottonelle flushable wet wipes, which are pre-moistened disposable wipes designed for personal hygiene. They are made of nonwoven cloth-like material (basesheet), that is flushable in that it weakens and disperses when agitated in water. The proprietary cleansing solution is manufactured in South Korea using ingredients sourced from various countries. |
| Reason: The South Korean proprietary cleansing solution imparts the finished product’s essential character, and the Chinese basesheet material serves as the carrier. |
| Ruling Date: Sept. 8, 2025 |
N352220: The country of origin and eligibility of the United States-Mexico-Canada Trade Agreement (“USMCA”) for beeswax candles
| USMCA Eligibility: Yes |
| Item: The products under consideration are handmade pure beeswax candles. The candles are made wholly from beeswax that is produced using 100% Canadian beeswax. Most of the wicks are sourced from Canada, with a small number coming from the United States. |
| Reason: Since the subject candles are produced entirely in Canada exclusively from Canadian beeswax and Canadian or United States sourced wicks, they are considered originating under GN 11(b)(ii). |
| Ruling Date: Sept. 8, 2025 |
N352314: The country of origin of Lulu® Nail Polish Collection
| Origin: Malaysia or Vietnam |
| Item: The Lulu Nail Polish Collection contains 14 mini nail polishes (0.07 fluid ounce) in various colors including purple, blue, green, pink, yellow, silver glitter, and others. The raw materials used to produce the finished nail polishes include humectants, preservatives, solvents, and cosmetic colorants. The raw materials will be sent to either Malaysia or Vietnam where they will be weighed and blended under controlled conditions using a mixing machine to produce a stable bulk. |
| Reason: The production process in Malaysia or Vietnam results in a substantial transformation of the raw materials into the nail polishes. |
| Ruling Date: Sept. 8, 2025 |
N352371: The classification, origin, marking, and eligibility under subheading 9802.00.5060 on jewelry
| HTS: 7113.19.5090, 9802.00.5060, 5.5%, “Articles of jewelry and parts thereof, of precious metal or of metal clad with precious metal: Of other precious metal, whether or not plated or clad with precious metal: Other: Other.” |
| Origin: U.S. |
| Item: Style GDOF9602G is a gold ring set with diamonds. The ring is cast in the U.S. and finished in Thailand or India. |
| Reason: The casting of the ring in the United States provides the essence of the finished product. Setting the gems and performing final finishing does not substantially transform the castings. |
| Ruling Date: Sept. 8, 2025 |
N352564: The country of origin of automotive air filters
| Origin: U.S. |
| Item: The items under consideration are described as automotive air filters, which are components of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The automotive air conditioning filters are assembled in Thailand using components from the United States, China, and Thailand. The filter media is from the United States. |
| Reason: The manufacturing and assembly process performed in Thailand is not considered complex. In this instance, the United States filter media is the primary filtering component of the finished filters. |
| Ruling Date: Sept. 8, 2025 |
N352583: The tariff classification, country of origin, and eligibility under the United States-Mexico-Canada Agreement (USMCA) for Hazelnut Oil, Walnut Oil, and Flaxseed Oil from Canada
| HTS: (Hazelnut Oil and Walnut Oil) 1515.90.2100, 9903.01.04; 9903.01.26, free, “Other fixed vegetable or microbial fats and oils (including jojoba oil) and their fractions, whether or not refined, but not chemically modified: Other: Nut Oils.” (Flaxseed Oil) 1515.11.0000, 9903.01.04; 9903.01.26, 6.3¢/kg, “Other fixed vegetable or microbial fats and oils (including jojoba oil) and their fractions, whether or not refined, but not chemically modified: Linseed oil and its fractions: Crude Oil.” |
| Origin: Canada |
| Item: The subject merchandise is cold-pressed organic hazelnut, walnut and flaxseed oils. The products consist of cold-pressed edible oils obtained from hazelnuts, walnuts, and flaxseeds. In each case, the raw nuts or seeds are grown and harvested in either Canada (hazelnuts and flaxseeds) or the United States (walnuts), and the pressing operations are carried out in Canada at temperatures below 40°C. |
| Reason: The subject merchandise is “produced exclusively from domestic materials,” namely from Canada and the United States. As such, Section 102.11(a)(2) applies to the facts presented in this case because the oils are made entirely from “domestic” materials. Therefore, in accordance with 19 C.F.R. §102.11(a)(3), the country of origin of the oil products is Canada. |
| Ruling Date: Sept. 8, 2025 |
N352713: The tariff classification and country of origin of regenerated cellulose sponge sheets
| HTS: 3921.14.0000, 9903.02.20, 6.5% + 8.5%, “other plates, sheets, film, foil and strip, of plastics: cellular: of regenerated cellulose.” |
| Origin: Germany |
| Item: A Swedish Dishcloth which will be used for household cleaning purposes, with the goal to reduce the use of paper towels. The sponge sheets are manufactured, in Germany, from a mixture of 70% cellulose, in the form of viscose, a dissolved liquid cellulose, and 30% scrap cotton fibers. The finished greige sheets are shipped to China where they will be printed and packaged for shipment to the United States. |
| Reason: The printing and packaging processes conducted in China constitute minor processing that does not result in a substantial transformation. |
| Ruling Date: Sept. 8, 2025 |
N352717: The country of origin of an automotive air filter
| Origin: Thailand |
| Item: The items under consideration are described as automotive air conditioning filters, which are components of the automotive heating, ventilation, and air conditioning (HVAC) system designed to clean the air entering the vehicle’s interior. The automotive air conditioning filters are assembled in Thailand using components from China and Thailand. |
| Reason: The manufacturing and assembly process performed in Thailand, including the creation of the filtration media, transforms the Chinese articles into a complete automotive air conditioning filter. The Thai-origin filter media is the primary filtering component of the finished filters and is also the most expensive article. |
| Ruling Date: Sept. 8, 2025 |