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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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N347268: The tariff classification of bicycle accessories from Taiwan

HTS: (Carbon Capsule Pro and PakLite Mini) 8512.10.4000, 9903.01.25, 2.7% + 10%, “Electrical lighting or signaling equipment…: Lighting or visual signaling equipment of a kind used on bicycles: Visual signaling equipment.” (PakBrite Fenders and Tri-Fin Mount) 8714.99.8000, 9903.01.25, 10% + 10%: “Parts and accessories of vehicles of headings 8711 to 8713: Other: Other: Other”
Item: The first item is the “Carbon Capsule Pro”, a rear bicycle safety taillight and storage compartment accessory for bicycles. The accessory is for outdoor and recreational cycling use. The integrated LED (Light-Emitting Diode) light enhances rear visibility. The second item has been identified as the “PakLite Mini”, a rear-mounted safety light that attaches to the bicycle seat post using a quick-release rubberized strap. The third item is the “PakBrite Fenders”, a modular bicycle accessory designed to minimize spray and debris from the wheels during outdoor and recreational cycling. The fourth, and final item, has been identified as the “Tri-Fin Mount”, a proprietary bicycle accessory mounting system designed by PakBrite, which serves as a universal attachment point for various PakBrite products, including the rear safety lights, storage capsules, and fenders.
Reason: N/A
Ruling Date: April 17, 2025

N347296: The tariff classification of a padded vest from Vietnam

HTS: 6201.40.6020, 9903.01.25, 14.9% + 10%, “Men’s or boys’ overcoats, carcoats, capes, cloaks, anoraks (including ski jackets), windbreakers and similar articles (including padded, sleeveless jackets), other than those of heading 6203: Of man-made fibers: Anoraks (including ski-jackets), windbreakers and similar articles (including padded, sleeveless jackets): Other: Other: Padded, sleeveless jackets: Other.”
Item: A men’s padded vest constructed from knit and woven fabric components. The collar; front yoke, which extends into the back yoke; and the back panel are constructed from 95% polyester 5% spandex knit fabric heavily brushed on the inside. The balance of the garment (front panels sans the shoulder yoke) is constructed from 100% polyester shell fabric insulated with polyfill batting and quilted in horizontal rows to a 100% polyester lining fabric. The padded vest features a full front opening with a zipper closure that extends to the top of a stand-up collar, a storm flap, zippered welt pockets below the waist, elastic binding armholes, and a straight hemmed bottom. The armholes are cut to accommodate wear over other bulky clothing. Neither the knit fabric nor the woven fabric exceeds 60% of the surface area of the garment. Both fabrics play an important role in the garment and neither impart the essential character.
Reason: N/A
Ruling Date: April 17, 2025

N347320: The classification of an etagere (open shelf unit) from India

HTS: 9403.89.6015, 9903.01.25, free + 10%, “Other furniture and parts thereof: Furniture of other materials, including cane, osier, bamboo or similar materials: Other: Other: Other household.”
Item: The subject article is identified as the Keswick Bronze and the Keswick Black Etagere. The article measures 38" (W) x 18" (D) x 78" (H) and has a hand-distressed wrought iron frame with five natural Banswara marble shelves. It is available in either a black iron or textured bronze finish. It is intended for household use and made in India.
Reason: The marble shelves provide the article’s display surface, and the wrought iron frame supports the shelves and provides the article’s structure and dimensions. Neither component can function alone, and neither component is more important to the functionality of the article than the other. The shelves and frame are of similar visual importance. No essential character can be determined under GRI 3(b), so it will be classified in accordance with GRI 3(c), last in tariff.
Ruling Date: April 17, 2025

N347344: The tariff classification of cable reels and accessory covers from Germany

HTS: (cable reels) 8479.89.9599, 9903.01.25, 2.5% + 10%, “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.” (accessory covers) 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 products in question are several models of drum-shaped, hand crank cable reels (“cable reels” or “reels”), and plastic accessory and auxiliary winding drum covers (“accessory covers”) which will be imported either with the reels, or separately. The cable reels are used in the broadcast, military, electrical, medical, and various other industries to wind, organize, protect and transport cables, fiber optic cables, hoses, rope and any other flexible cable, tubes, or linear objects. The reels will be imported without cable or other winded material. The accessory covers are used with the cable reels to cover the drum’s core opening/axle and protect the cable/fiber terminations from contaminants, with certain styles providing some ancillary storage to the reel.
Reason: N/A
Ruling Date: April 17, 2025

N347381: The tariff classification of an outsole roughing and sanding machine from Italy

HTS: 8477.80.0100, 9903.01.25, 3.1% + 10%, “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter; parts thereof: Other machinery.”
Item: The product in question is the Flexorobot 3D Milling and Scouring machine (“Flexorobot”). It is a robotized workstation for roughing and sanding footwear outsoles. As imported, the Flexorobot will include a rotating table for 3D blue light scanning of the shoe’s profile to determine the roughing and sanding parameters, a 6-axis robot to handle the footwear during processing, a milling (roughing) machine, a sanding machine, and an exit conveyor with an air knife.
Reason: N/A
Ruling Date: April 17, 2025

N347383: The tariff classification of a Painting Art Kit from China

HTS: 3213.10.0000, 9903.01.24, 9903.01.63, 9903.88.03, 6.5% + 20% + 125% + 25%, “Artists’, students’ or signboard painters’ colors, modifying tints, amusement colors and the like, in tablets, tubes, jars, bottles, pans or in similar forms or packings: Colors in sets.”
Item: The kit consists of 6 small paint pods in assorted colors, 1 plastic paint brush, and 4 small plaster objects depicting Halloween themed creatures (an Owl wearing a hat, a Frankenstein's Monster, a Vampire, and a Cat wearing a hat). The paints and paint brush will be used to creatively paint the plaster objects for a Halloween themed activity. The Painting Art Kit is packaged for retail sale and recommended for ages 6 and older.
Reason: The Painting Art Kit will be classified as a set for tariff classification purposes in accordance with GRI 3(b), with the essential character imparted by the paints and paint brush (colors in sets), based on their role in relation to the product’s use.
Ruling Date: April 17, 2025

N347442: The tariff classification of a quilted outdoor blanket from China

HTS: 6307.90.9891, 9903.01.24, 9903.01.63, 9903.88.15, 7% + 20% + 125% + 7.5%, “Other made up articles, including dress patterns: Other: Other: Other: Other: Other.”
Item: A “CLB Waterproof Outdoor Blanket” is designed and intended to be used outdoors to sit or lay on while camping, picnicking, or attending outdoor activities. The blanket consists of three layers quilted together: a 100% polyester woven printed face fabric with water-resistant coating; a 100% polyester nonwoven batting middle layer; and a 100% polyester woven dyed backing fabric laminated with a thermoplastic polyurethane (TPU) film. The square shaped blanket measures 72 inches by 72 inches and is bound along the edges with a 100% polyester oxford fabric. The blanket is designed to be rolled up for transport and storage with a hook-and-loop closure. It features a webbed handle, a removeable, adjustable webbed shoulder strap, two carabiner-like clips, and four webbed loops at each of the corners intended to be used to secure to the ground, if desired. The blanket is not sold with metal stakes. The blanket also features a leather patch imprinted with the brand name, Columbia® on the front, bottom, right corner, and a printed “Columbia®” logo on the textile flap.
Reason: N/A
Ruling Date: April 17, 2025

N347466: The tariff classification of wrestling shoes from Vietnam

HTS: 6402.19.1520, 9903.01.25, 5.1% + 10%, “other footwear with outer soles and uppers of rubber or plastics: Sports footwear: Other: Having uppers of which over 90 percent of the external surface area (including accessories or reinforcements such as those mentioned in note 4(a) to this chapter) is rubber or plastics (except footwear having foxing or a foxing-like band applied or molded at the sole and overlapping the upper and except footwear designed to be worn over, or in lieu of, other footwear as a protection against water, oil, grease or chemicals or cold or inclement weather): Other: For men.”
Item: ASICS brand MATFLEX 8 is a men’s, above the ankle, below the knee, lace-up, wrestling shoe. The external surface area of the upper consists of 91.96% polyurethane (PU) - synthetic leather and synthetic suede, and 8.04% textile. The PU upper material overlaps approximately 40% of the rubber/plastics outer sole. It is not considered to have a foxing or a foxing-like band.
Reason: N/A
Ruling Date: April 17, 2025

N347490: The tariff classification of a connecting rod from South Korea

HTS: 8409.91.5010, 9903.01.25, 2.5% + 10%, “Parts suitable for use solely or principally with the engines of heading 8407 or 8408: Suitable for use solely or principally with spark-ignition internal combustion piston engines (including rotary engines): Other: To be installed in vehicles of subheading 8701.21, 8701.22, 8701.23, 8701.24 or 8701.29, or heading 8702, 8703 or 8704: Other: Connecting rods.”
Item: The item under consideration has been identified as a “connecting rod”. A connecting rod is the part of a piston engine which connects the piston to the crankshaft. Together with the crank, the connecting rod converts the reciprocating motion of the piston into the rotation of the crankshaft. The connecting rod is attached to the piston by a swiveling wrist pin. The pin is mounted within the piston.
Reason: N/A
Ruling Date: April 17, 2025

N347592: The tariff classification of a child’s backpack and toys from China

HTS: (backpack) 4202.92.3120, 9903.01.24, 9903.01.63, 9903.88.03, 17.6% + 20% + 125% + 25%, “travel, sports, and similar bags, with outer surface of textile materials, of man-made fibers, backpacks.(toy products) 9503.00.0071, 9903.01.24, 9903.01.63, free + 20% + 125%: “Tricycles, scooters, pedal cars and similar wheeled toys…dolls, other toys…puzzles of all kinds; parts and accessories thereof… ‘Children’s products’ as defined in 15 U.S.C. § 2052: Other: Labeled or determined by importer as intended for use by persons: Under 3 years of age.”
Item: The article at issue consists of a child’s backpack and toys (a polypropylene granola bar, a silicone popper with carabiner, three felt bandages, a polypropylene carrying case, non-functional polypropylene walkie talkie, and water bottle made of ABS and polypropylene.) The child’s backpack is made of 100% polyester, which is a man-made textile material. The backpack is designed to provide storage, protection, organization, and portability to the child’s personal effects during travel. It features one main compartment with a bear face flap. It secures with hook-and-loop fasteners. The front features one pocket. The back of the pack has two straps that allow the child to wear it over the shoulders on the back.
Reason: N/A
Ruling Date: April 17, 2025