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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N334072: The country of origin of a dimmer switches
| Country of Origin: Vietnam |
| Items: Paddle-style electrical switches with additional dimming slide switches. The switches are intended to be used to control the operation of residential lighting and each is comprised of a printed circuit board assembly, a molded plastic body, a metal mounting plate, terminals, a heat sink, and more. The dimmer is assembled in Vietnam from components sourced from China. |
| Reason: The assembly of the PCBA in Vietnam by soldering the individual components onto the bare board results in a substantial transformation of the individual components to produce a PCBA of Vietnamese origin. The PCBA utilized in each of the dimmer switches establishes the function of the switch because it is the article within the assembly that opens and closes the electrical circuit and provides the dimming function. |
| Ruling Date: Aug. 2, 2023 |
N334127: The tariff classification of three novelty tables and a novelty liquor cabinet from India
| HTS: 9403.20.0050, free, “Other furniture and parts thereof: Other metal furniture: Household: Other: Other.” |
| Item: A bar table made to resemble an easy rider-style motorcycle. The base is made predominantly of metal. The tear-drop gas tank and both fenders are painted in a red, white, and blue American flag motif. Above the seat and rear wheel is a rustic wooden tabletop. |
| Reason: N/A |
| Ruling Date: Aug. 2, 2023 |
N334192: Country of origin and marking determination for an infants’ blanket; 19 CFR 102.21(c)(2)
| Country of Origin: China |
| Item: An infants’ blanket comprised of a single layer of 96% viscose and 4% elastane jersey knit, printed, fabric. The blanket will be imported in two styles: Style IQ963010 (rainbow print) and Style IQ963210 (sailboat print). Each blanket measures 30 × 40 inches and has rounded corners. Self-fabric binding is sewn around the edges. |
| Reason: As the fabric comprising the infants’ blanket is formed in a single country of China, per the terms of the tariff shift requirement, country of origin is conferred in China. |
| Ruling Date: Aug. 2, 2023 |
N334327: The country of origin of a dimmer switches
| Country of Origin: Vietnam |
| Items: Paddle-style electrical switches with additional dimming slide switches. The dimmer is intended to be used to control the operation of residential lighting and each is comprised of a printed circuit board assembly, a molded plastic body, a metal mounting plate, terminals, and more. The switches are assembled in Vietnam from components sourced from China. |
| Reason: The assembly of the PCBA in Vietnam by soldering the individual components onto the bare board results in a substantial transformation of the individual components to produce a PCBA of Vietnamese origin. The PCBA utilized in each of the dimmer switches establishes the function of the switch because it is the article within the assembly that opens and closes the electrical circuit and provides the dimming function. |
| Ruling Date: Aug. 2, 2023 |
N334203: The tariff classification of a Foot Work reflexology kit from China
| HTS: 9019.10.2050, free, Mechano-therapy appliances; massage apparatus … : massage apparatus: other.” |
| Item: A Foot Work reflexology kit. It is comprised of a foot roller massage tool of Schima wood, one pair of knitted socks, printed with a reflexology chart on the bottom, and an eight-page printed paper instruction booklet. The components are packaged for retail sale in a paperboard canister. The user is instructed in the use of the foot roller for general foot massage, to be followed by targeted massage using the reflexology chart printed on the socks. |
| Reason: N/A |
| Ruling Date: Aug. 1, 2023 |
N333816: The tariff classification of a pouch with decorating materials from China
| HTS: 4202.92.1500, 9903.88.03, 6.3% + 25%, "Travel, sports, and similar bags, with outer surface of textile materials, of vegetable fibers and not of pile or tufted construction, of cotton." |
| Item: A reusable pouch, an instruction booklet, three bottles of dye powder, ten rubber bands, and disposable gloves. The dye powders and other components are used to tie dye the pouch. The outer surface of the pouch is constructed of one hundred percent cotton textile material. The pouch is designed to provide storage, protection, portability, and organization to personal effects during travel. It features a zippered closure. |
| Reason: N/A |
| Ruling Date: July 31, 2023 |
N333821: The tariff classification of a bracelet making kit from China
| HTS: 7117.90.7500, free, “Imitation jewelry: Other: Other: Valued over 20 cents per dozen pieces or parts: Other: Of plastics.” |
| Item: A bracelet making kit packaged in a retail-ready box and is marketed for adults. It includes plastic beads, a sewing needle, a wax cord, a flat woven cord, thread, and a 32-page instruction booklet. The kit also includes base metal: beads, chain, lobster clasps, wire, and jump rings. |
| Reason: N/A |
| Ruling Date: July 31, 2023 |
N333773: The tariff classification of dental cements in retail packings from the United States
| HTS: 3006.40.0000, free, “Dental cements and other dental fillings; bone reconstruction cements.” |
| Item: Dental cement imported in refill syringes and used to affix dental brackets to patients' teeth |
| Reason: N/A |
| Ruling Date: July 28, 2023 |
N333892: The country of origin of Adapalene Gel USP 0.3%
| Country of Origin: Spain |
| Item: Adapalene Gel USP 0.3%, imported in 45 grams tubes, is a topical retinoid. It is indicated for the topical treatment of acne vulgaris in patients 12 years of age and older. |
| Reason: The mixing of the active ingredient Adapalene (made in Spain) with the inactive ingredients into the final Adapalene Gel 0.3% in dosage form doesn't result in a substantial transformation. |
| Ruling Date: July 28, 2023 |
N333916: The country of origin of a glue stick
| Country of Origin: China |
| Item: A 0.32 oz. glue stick. The cap/tube is made from polypropylene and the core/base is made from high-density polyethylene in Vietnam. The glue is composed of water, polyvinylpyrrolidone, glycerol, propylene glycol, sodium stearate, 2-phenoxyethanol, and chlorphenesin. |
| Reason: The glue in the glue stick is made by mixing water and PVP, heating and dissolving PVP, mixing with other additives, and cooling the mixture to form the glue. The heat treatment, which merely dissolves PVP from liquid form into a transparent solution, does not result in a substantial transformation. |
| Ruling Date: July 28, 2023 |