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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N348520: The tariff classification of CHAPS (CAS # 75621-03-3) from China
| HTS: 3402.49.9000, 9903.01.24, 9903.01.25, 9903.88.03, 3.7% + 20% + 10% + 25%, “Organic surface-active agents (other than soap); surface-active preparations, washing preparations (including auxiliary washing preparations) and cleaning preparations, whether or not containing soap, other than those of heading 3401: Other surface-active agents, whether or not put up for retail sale: Other: Other.” |
| Item: The subject product is identified as CHAPS (CAS # 75621-03-3), which has a chemical name of3-[(3-Cholamidopropyl) dimethylammonio]-1-propanesulfonate and molecular formula of C32H58N2O7S. CHAPS is a white powder chemical compound, known as a zwitterionic surface-active agent. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348526: The tariff classification of Calcium Lactate Pentahydrate USP (CAS No. 5743-47-5) from China
| HTS: 2918.11.5100, 9903.01.24, 9903.01.32, 9903.88.03, 3.4% + 20% + 10% + 25%, “Carboxylic acids with alcohol function but without other oxygen function, their anhydrides, halides, peroxides, peroxyacids and their derivatives: Lactic acid, its salts and esters: Other.” |
| Item: The subject product, Calcium Lactate Pentahydrate USP is also known as L-Lactic acid calcium salt. It is a salt of lactic acid used in the food industry. It will be imported in bulk form. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348575: The tariff classification of foot massagers from China
| HTS: 9019.10.2045, 9903.01.24, 9903.01.25, free + 20% + 10%, “[m]echano-therapy appliances; massage apparatus …: [m]assage apparatus: [e]lectrically operated: [o]other: [other].” |
| Item: The products under consideration are identified as MedMassager’s Foot Massager Classic and Foot Massager Plus, which feature an inclined surface. Both foot massagers measure 15” x 12” x 9.5” and feature a full-sized foot pad with rubber nubs, an arch bar across the top of the foot pad, slip resistant feet, 110 V 60 Hz electric power, and an adjustable knob or switch to control the speed. They are nearly identical except the classic model is 10 lbs. and has a 3,300 RPM motor and two speeds. The Plus model is 11 lbs. and has 4000 RPM motor and 11 variable speeds. Both massagers use oscillating technology that combines vibration and circular rotation to deliver targeted pressure and oscillating massage. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348634: The tariff classification of a mobility cane from China
| HTS: 6602.00.0000, 9817.00.96, free, “Walking sticks, seat sticks, whips, riding crops and the like.” |
| Item: The product under consideration is the “Strong Arm Comfort Cane.” The Strong Arm Comfort Cane is an ergonomic mobility cane that can be used with both right and left arms. It is made of aluminum tube, is height adjustable, and supports up to 500lbs. The cane consists of two sections, the lower section consisting of height-adjusting tubes and a molded rubber foot that allows the cane to be self-standing. The upper section is made of aluminum and has a straight section, a handgrip and a “S” shaped forearm cradle. The hand grip and forearm cradle are covered in EVA foam for added grip and comfort. The forearm support cradle helps shift weight off the user’s wrist onto their forearm. At the lowest setting, the cane measures 28 inches from the hand grip to the bottom of the tip and 39 inches when set to the tallest setting. |
| Reason: The Strong Arm Comfort Cane is an article specially designed or adapted for the handicapped and is not precluded by Note 4(b) as articles for individuals with acute or transient disabilities. Therefore, it is eligible for duty-free treatment under subheading 9817.00.96, Harmonize Tariff Schedule of the U.S. |
| Ruling Date: May 22, 2025 |
N348696: The country of origin of facial tissue
| Origin: Indonesia |
| Item: The paper product under consideration are packages of "facial tissue." They come in double or triple ply with 1/2 fold. The bulk rolls of facial tissue stock are manufactured in Indonesia. The paper is White/Kraft 100% wood pulp virgin paper; layer: 2; 12-15 g/sm. These parent rolls of tissue paper, which measure 1470mm in width and have a maximum roll diameter of 1470mm, are then sent to China, where the tissue paper is embossed, folded and cut to length and width with no shaping. The facial tissue is then subjected to quality control and packaged. |
| Reason: In China the facial tissue stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, folding, cutting, and packaging. The country of origin of the finished facial tissue is Indonesia. |
| Ruling Date: May 22, 2025 |
N348702: The country of origin of a 7-inch LCD monitor
| Origin: China |
| Item: The merchandise under consideration is a 7-inch liquid crystal display (LCD) monitor, which is for use in a vehicle. The monitor is intended for car reversing applications. In China, the manufacturing process starts with production of the main board, control board, cables, and remote control. Then, the components are shipped to Taiwan. In Taiwan, the LCD panel, mount, housing, etc. are produced. The components from China and Taiwan are then assembled, tested and packaged in Taiwan. First, the mainboard, control board, and LCD panel are assembled into the mechanical housing (front and rear casings). Next, the cable is connected, and the connections and internal structure are fixed. Last, the stand, power module, and mechanical accessories are installed. |
| Reason: The origin of the monitor is the country in which the underlying main PCBA (main board) is produced. Accordingly, the Chinese main board imparts the prominent character of the device since it performs the primary and vital functions of the monitor, which is forming images for display. Further, in this case, the main board (PCBA) is made in China and the assembly process performed in Taiwan would not substantially transform the main board into a new and different article of commerce with a name, character, and use distinct from that of the exported good. As a result, the country of origin of the subject monitor is China. |
| Ruling Date: May 22, 2025 |
N348746: The tariff classification of two brim biters from China
| HTS: 7116.20.0500, 9903.01.24, 9903.01.25, 3.3% + 20% + 10%, “Articles of natural or cultured pearls, precious or semi-precious stones (natural, synthetic or reconstructed): Of precious or semiprecious stones (natural, synthetic or reconstructed): Articles of jewelry: Valued not over $40 per piece: Other.” |
| Item: The articles at issue are two brim biters. They are marketed and specifically designed to be adorned or displayed on the brim of a hat. Each brim biter will be individually packaged on a retail blister card. Sample A: N1505 is shaped like a snake and composed of brass, turquoise and cubic zircon. Sample B: N1516 is composed of brass and cubic zircon. |
| Reason: N/A |
| Ruling Date: May 22, 2025 |
N348790: The country of origin of a fiberglass measuring reel
| Origin: Korea |
| Item: The item under consideration is described as a fiberglass measuring reel, which is a device to measure distances between two points by use of a printed fiberglass tape. The device is designed to be staked to the ground and then pulled to the required length. Alternatively, the user can attach the ring-hook to the beginning point to be measured and then the whole unit pulled to the desired length. To lock the tape in place, the user would flip the handle up into the reel which then prevents the tape from moving. The fiberglass measurement strip is flexible, which permits one to measure around curves or corners. The fiberglass measuring tapes are produced, printed, cut, and rolled in the Republic of Korea. The bulk rolls are then shipped on a spool from the Republic of Korea to Vietnam. In Vietnam, the final tape reel is assembled with the remaining Vietnamese components which include the plastic case, handle, ground stake, ring hook, lever drum, washer, rubber wings, bobbin, brush, bit, and screws. The fiberglass tape makes up over half of the overall cost of the finished article. The additional components are wrapped around the Korean fiberglass tape and the ring hook, ground stake, handle, bobbin, brush, and outer casings are attached by screws, which lock the components in place. The finished fiberglass tape reel is then packaged for retail sale before export to the United States. |
| Reason: The additional parts added in Vietnam do not change the essential function of the fiberglass printed reel. Consequently, the simple assembly process in Vietnam, which predominantly involves placing, snapping, and screwing components into place, does not result in a new product having a distinctive name, character, or use. Therefore, the good remains a product of the Republic of Korea, which is where the fiberglass measuring tape is manufactured. |
| Ruling Date: May 22, 2025 |
N348873: The country of origin of toilet seat covers
| Origin: China |
| Item: The paper products under consideration are "toilet seat covers." They come in single ply with either 1/2 or 1/4 fold. The bulk rolls of toilet seat cover stock are manufactured in Indonesia. The paper is White/Kraft 100% wood pulp virgin paper; layer:1; 12-18g/sm. These parent rolls of tissue paper, which measure in multiple widths from 420mm up to 430mm and have a maximum roll diameter of 380mm, are then sent to China, where the paper is embossed, cut and folded to length and width. The toilet seat covers are then subjected to quality control and packaged. |
| Reason: In China the toilet seat cover stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting, folding and packaging. The country of origin of the finished toilet seat cover is Indonesia. |
| Ruling Date: May 22, 2025 |
N348875: The country of origin of exam table paper
| Origin: Indonesia |
| Item: The paper products under consideration are "exam table paper." They come in single ply, rolls. The bulk rolls of exam table paper stock are manufactured in Indonesia. The paper is White/Kraft 100% wood pulp virgin paper; layer:1; 12-18g/sm. These parent rolls of tissue paper, which measure in multiple widths from 457mm up to 686mm and have a maximum roll diameter of 380mm, are then sent to China, where the paper is embossed, cut to length and width with no shaping done. The rolls of exam table paper are then subjected to quality control and packaged. |
| Reason: In China the exam table paper stock does not undergo a substantial transformation resulting in an item with a new name, character or use simply by embossing, cutting and packaging. The country of origin of the finished exam table paper is Indonesia. |
| Ruling Date: May 22, 2025 |