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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N348876: The tariff classification of pumps from Germany and a valve and sensor from China
| HTS: (Ultrafilter Pump) 8413.60.0090, 9903.01.25, free + 10%, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Other rotary positive displacement pumps: Other: Other.” (piston pumps) 8413.50.0090, 9903.01.25, free + 10%, “Pumps for liquids, whether or not fitted with a measuring device; liquid elevators; part thereof: Other reciprocating positive displacement pumps: Other: Other.” (level detector sensor) 9026.10.2080, 9903.01.25, 9903.01.24, free + 10% + 20%, “Instruments and apparatus for measuring or checking the flow, level, pressure or other variables of liquids or gases (for example, flow meters, level gauges, manometers, heat meters), excluding instruments and apparatus of heading 9014, 9015, 9028 or 9032; parts and accessories thereof: For measuring or checking the flow or level of liquids: Electrical: Other.” (Carbon Flush Valve) 8481.80.9005, 9903.01.25, 9903.01.24, 2% + 10% + 20%, “Taps, cocks, valves and similar appliances, for pipes, boiler shells, tanks, vats or the like, including pressure-reducing valves and thermostatically controlled valves; parts thereof: Other appliances: Other: Solenoid valves.” |
| Item: The five products at issue are installed in the Tablo Hemodialysis System Console, which provides hemodialysis treatment for individuals with End-Stage Renal Disease (ESRD). The console, which features four wheels, is comprised of a housing equipped with various components that together remove toxins, waste and fluid from the body. The Ultrafilter Pump is a component of the console’s water purification subsystem, which produces dialysis-grade water from tap water. The gear pump transports water from the reverse osmosis filtration system to a downstream ultrafilter. The pump features tubing connections that interface with the console, and the pump’s electrical connectors and signal pin configurations are specifically compatible with the console’s electronics and software. The Dialysate Piston Pump regulates the flow of dialysate fluid to the dialyzer filter, which is used to extract toxins from the blood. The stroke volume of the pump is calibrated to achieve the range of flow rates necessary for dialysis treatments. The motorized pump features tubing connections that interface with the console, and the pump’s electrical connectors and signal pin configurations are specifically compatible with the console’s electronics and software. The Bicarbonate Piston Pump meters the flow of bicarbonate solution used in the production of dialysate, which is used to remove toxins from the user’s bloodstream. The stroke volume of the pump is calibrated to deliver the flow rates required for dialysis. The motorized pump features tubing connections that interface with the console, and the pump’s electrical connectors and signal pin configurations are specifically compatible with the console’s electronics and software. The level detector sensor is an electronic sensor designed to detect the presence of air or water within the air separation chamber of the console. The console is used to remove dissolved air from the purified water prior to the production of dialysate solution. The sensor is designed to interface mechanically with the air removal chamber and detect when air has accumulated in the chamber and needs to be pumped out of the chamber. The sensor’s electrical connectors and signal pin configurations are specifically designed for compatibility with the console’s electronics and software. The sensor is sourced from China. The Carbon Flush Valve is a three-way solenoid valve. Once actuated, the valve removes excess carbon from the carbon filters located in the console’s water purification subsystem. The copper valve is designed to be installed onto a custom designed manifold, and the electrical connectors and signal pin configurations are specifically compatible with the console’s electronics and software. The valve is sourced from China. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348916: The tariff classification the “Stringprotech” from China
| HTS: 9209.92.8000, 9903.01.24, 9903.01.63, 9903.88.15, 4.6% + 20% + 10% + 15%, “Parts…and accessories…of musical instruments…: Other: Parts and accessories for the musical instruments of heading 9202: Other.” |
| Item: The “Stringprotech” is an accessory intended for use with stringed musical instruments, particularly guitars. It is rectangular in shape and covers the strings of the instrument when not in use, offering protection against oxidation, corrosion, and environmental damage. The “Stringprotech” is reusable and serves to extend the life and quality of strings by preventing exposure to air, moisture, and physical damage. It is made of injection molded plastic with a soft internal lining shaped to fit the curvature and tension pattern of standard guitar strings. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348930: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: Five models of a fiber optic patch cord assembly. The subject assemblies are further described as fiber optic cables that consist of a fiber optic core, which consists of 2, 12, 192, or 288 optical fibers depending on the model number. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The subject cables are used within various telecommunications industries to transfer optical data signals. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and prepared for the addition of the connectors, which are sourced from the U.S. and China. The connectors are then assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S. |
| Reason: Regarding the origin of the subject fiber optic cable assemblies, 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. Based upon the facts presented, the origin of the fiber optic patch cord assembly will be the U.S. |
| Ruling Date: May 22, 2025 |
N348990: The country of origin of patch cord assemblies
| Origin: U.S. |
| Item: Five models of a fiber optic patch cord assembly. The subject assemblies are further described as fiber optic cables that consist of a fiber optic core, which consists of 2, 12, 16, or 24 optical fibers depending on the model number. The fibers are enclosed within a jacket and are terminated with a single connector at one end and fanned out to various optical connectors at the other. The subject cables are used within various telecommunications industries to transfer optical data signals. The manufacturing process for all 5 parts is substantially similar and begins with the creation of the optical fiber in the United States. This process begins with the melting and stretching of the glass raw material into a glass bar. This bar is then ground and cleaned before it is further stretched and drawn into the appropriate length and diameter for the individual optical fiber. This fiber is then coated with polymer and tested for strength and function before it is exported to China. In China, the fiber core is cut to length prior to being colored and jacketed. The ends are then fanned out and prepared for the addition of the connectors, which are sourced from the U.S., China and India. The connectors are then assembled onto the ends and the finished cable is tested and packaged for shipment to the U.S. |
| Reason: Regarding the origin of the subject fiber optic cable assemblies, 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. Based upon the facts presented, the origin of the fiber optic patch cord assembly will be the U.S. |
| Ruling Date: May 22, 2025 |
N349040: The tariff classification of a playground slide from the Czech Republic
| HTS: 9506.99.6080, 9903.01.25, 4% + 10%, "Articles and equipment for general physical exercise, gymnastics, athletics, other sports…or outdoor games…; swimming pools and wading pools; parts and accessories thereof: Other: Other: Other…Other." |
| Item: The slide measures approximately 161” x 119” when assembled and has a 34” diameter opening. It will be shipped directly to the final user as a single sale and will not be sold in stores. The tubular slide is designed for use by children. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N349200: The tariff classification of a ceramic decoration from China
| HTS: 6913.90.5000, 9903.01.24, 9903.01.25, 9903.88.15, 6% + 20% + 10% + 7.5%, “Statuettes and other ornamental ceramic articles: Other: Other: Other.” |
| Item: The product is a decorative ceramic lantern. The article measures approximately 4.00 inches long by 4.00 inches wide by 5.75 inches high. The yellow lantern is square and made of dolomite ceramic. Its inside bottom contains a flat surface. The lantern features a yellow floral cutout design in the center. An iron handle is attached to the article, which is used to carry it. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348089: The tariff classification of casters and wheel assemblies from France
| HTS: (1) and (4) 8302.20.0000, 9903.01.25, 5.7% + 10%, “Base metal mountings, fittings and similar articles…Castors, and parts thereof.” (2), (3) and (5) 3926.90.9989, 9903.01.25, 5.3% + 10%: “Other articles of plastics and articles of other materials of headings 3901 to 3914: Other: Other: Other.” |
| Item: The first item (1) is a swivel caster that will be used solely on a Spectra Optia Apsheresis System. The housing and the center of the wheel are made of polyamide, the wheel tread is made of polyurethane, and the mounting stem is made of steel. The wheel diameter is 125 mm, and the wheel width is 15 mm. The second item (2) is a plastic caster that will be used solely on a Spectra Optia Apsheresis System. This wheel assembly lacks a metal stem. The third item (3) is plastic casters that will be used solely on a medical bassinet for babies to sleep in while in the hospital after birth. These wheel assemblies lack metal stems. The fourth item (4) is a swivel caster that will be used solely on an INOmax DSIR system. The housing and the center of the wheel are made of polyamide, the wheel tread is made of polyurethane, and the mounting stem is made of steel. The wheel diameter is 125 mm, and the wheel width is 20 mm. The fifth item (5) is a plastic caster that is used solely on a Cori Surgical System. This wheel assembly lacks a metal stem. |
| Reason: N/A |
| Ruling Date: May 21, 2025 |
N348296: The country of origin of steel wheels
| Origin: Thailand |
| Item: The articles under consideration are steel wheels, which are used in automotive applications. They are mainly composed of two key components: the rim and the disc. The rim is manufactured in Thailand, while the disc is sourced from China to be assembled with the rim to create a complete steel wheel. The rim is produced using the roll-forming process. In this process, a steel plate is gradually bent into shape through multiple sets of rollers. After precise size control and shape adjustment, a rim is formed. This process ensures the accuracy and consistency of the rim, providing its strength and rigidity. The disc is mostly processed using the stamping process. Through one or more stamping operations, the disc structure is shaped to meet both mechanical performance and aesthetic requirements. The rim and disc are then joined together in a single unit through the welding process in Thailand. Additionally, to enhance the anti-corrosion performance and aesthetics of the steel wheels, they undergo a surface treatment process, which includes painting and electroplating. The painting process forms an anti-corrosion coating on the wheel surface through methods such as spraying or dipping, isolating the wheel from the external environment. The electroplating process deposits a layer of metal on the wheel surface, which not only improves the wheel's anti-corrosion ability but also gives it a unique appearance. |
| Reason: Both main components, the rim and the disc, are integral components of the finished wheel. Taking into consideration the fact that final assembly involving significant processing occurs in Thailand and the value of the Thai components and additional labor amounts to approximately 89% of the total value, a substantial transformation occurs in Thailand. Accordingly, the country of origin of the steel wheels will be Thailand. |
| Ruling Date: May 21, 2025 |
N348298: The country of origin of electric water filter dispensers
| Origin: China |
| Item: The electric water filter dispensers each comprise a transparent water tank, a water pumping unit and a tank lid. The water pumping unit contains a circuit board, a battery and a water purification filter element. The transparent water tank can be filled with tap water. The user can control the water by controlling the touch screen panel of the water applicator, and the water is then passed through the filter to remove dissolved solids and other impurities, and the clean water is always available. The electric water filter dispensers do not incorporate a heating or refrigerating device (function). They are designed solely for water filtration purposes and do not alter the temperature of the water. The products use components manufactured in the Republic of South Korea and China. The key component of the filter, the carbon block, is purchased from South Korea, while other components are finished parts purchased from various suppliers in China. The carbon block removes contaminants from water through a process called “adsorption.” |
| Reason: Except for the filter rods which are made in South Korea, all other parts or components, which substantial in number and account for the majority of production costs, are made in China. The manufacturing operations including the SMT process, rubber extrusion and plastic injection, along with other assembly activities in China, are complex and meaningful. Noting the filter rods are important components in the subject filter dispenser, the manufacturing process in China does create a new and different article of commerce with a distinct character and use that is not inherent in the components imported into China. Therefore, the country of origin of the electric water filter dispensers is China. |
| Ruling Date: May 21, 2025 |
N348317: The country of origin of Halstead Mosquito Forceps
| Origin: U.S. |
| Item: The Halstead Mosquito Forceps are small, straight, or curved instruments featuring fine, serrated jaws designed to securely hold and compress tissue and blood vessels. They are a type of surgical instrument primarily used to clamp blood vessels during delicate medical procedures in general surgery, dentistry, veterinary procedures and other medical disciplines requiring precise control of small vessels or other anatomical structures. Raw stainless steel is sourced from Germany and shipped to the United States. In the United States, the stainless steel is hot forged using a die and drop hammer to impart the final form and distinctive anatomical features of the forceps, including jaws, handles, and the hinge area. After forging, the part is annealed to relieve internal stresses and prepare it for subsequent refinement. At this stage the product has taken on its distinctive shape and is clearly identifiable as a medical instrument. In Pakistan, the following finishing and assembly operations are performed: minor excess material is removed (“flash”) from edges of the forging, machining and milling of serrations, box and rachet, insertion of boxlock pins, filing, heat treating, polishing, electropolishing, passivation, riveting, and final surface preparation. Next, the forceps are sent to Germany for final inspection, labelling, and packing before being exported to the United States. |
| Reason: The US operations, hot forging including drop hammering, and annealing, taken together transform the German raw stainless steel into a new product with changes in name, character, and use. This process in the United States gives the forceps the distinctive shape, character, and use, and results in a substantial transformation. The remaining operations in Pakistan are finishing and simple assembly operations and do not alter the overall shape, character, or use of the product. Accordingly, the country of origin of the Halstead Mosquito Forceps will be the United States. |
| Ruling Date: May 21, 2025 |