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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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N348879: The tariff classification of Dimethyl Octadecylamine (CAS No. 124-28-7) from China

HTS: 2921.19.6195, 9903.01.24; 9903.01.32; 9903.88.03, 6.5% + 20% + 25%, “Amine-function compounds: Acyclic monoamines and their derivatives; salts thereof: Other: Other: Other.”
Item: The subject product, dimethyl octadecylamine, CAS No. 124-28-7, is an acyclic monoamine. It is used as a friction modifier in lubricants and greases. It is also used as a surfactant in industrial processes and will be imported in 55-gallon drums.
Reason: N/A
Ruling Date: Aug. 22, 2025

N351636: The tariff classification, country of origin and eligibility under the United States-Mexico-Canada Agreement (USMCA) for a Sugar Lactose Cocoa Powder Blend (SLCBP) from Mexico

HTS: 1806.10.4500, 9903.01.14; 9903.01.26, 10% + 25%, “Chocolate and other food preparations containing cocoa: Cocoa powder, containing added sugar or other sweetening matter: Containing 90 percent or more by dry weight of sugar: Articles containing over 65 percent by dry weight of sugar described in additional U.S. note 2 to chapter 17: Described in additional U.S. note 7 to chapter 17 and entered pursuant to its provisions.”
USMCA Eligibility: Yes
Item: The subject merchandise is described as a Sugar Lactose Cocoa Powder Blend (hereinafter SLCBP) composed of a dry mixture of 94.9% refined sugar, 4.1% lactose powder, and 1% cocoa powder. The sugar in the SLCBP is stated to be grown and refined in Mexico and have a polarity of 99.9 degrees. The lactose is described as a product of the United States. The cocoa powder is said to be produced in the Netherlands from cocoa beans sourced from non-USMCA countries that include Ivory Coast, Ghana, Nigeria, and Cameroon. The ingredients are processed, blended, and packed in Mexico.
Reason: N/A
Ruling Date: Aug. 22, 2025

N351701: The classification, origin, marking, and eligibility under subheading 9802.00.5060 for 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: Several styles of gold jewelry which are cast in the U.S. and finished abroad.
Reason: The casting of the jewelry in the United States provides the essence of the finished product. Setting the gems and performing final finishing does not substantially transform the gold castings.
Ruling Date: Aug. 22, 2025

N351841: The eligibility of the United States-Mexico-Canada Agreement (USMCA) of Bitter Bianca Aperitif from Canada

USMCA Eligibility: Yes
Item: The subject merchandise is called Bitter Bianca. It is composed of spirits that contain neutral grain alcohol, lemon peel, orange peel, cinchona bark, gentian root, star anise, clove, dandelion, elderflower, wormwood, pear, and sugar.
Reason: No nonoriginating alcoholic ingredients are used in the production of the good. Therefore, the rule of origin is satisfied.
Ruling Date: Aug. 22, 2025

N351865: The tariff classification and country of origin of pressure sensors

HTS: 9026.20.4000, 9903.02.66, free + 10%, “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 pressure: Electrical.”
Origin: U.K.
Item: The items under consideration are described as ultra-low-pressure sensors (APP-9U Series) designed for applications requiring precise measurement of very low pressures, such as heating, ventilation, and air conditioning (HVAC) units. The die (which is a piece of silicon containing a complete integrated circuit that has been cut from a larger silicon wafer) is designed and manufactured in the United Kingdom and contains all of the sensor’s electronic functionality.
Reason: The die from the United Kingdom has all of the sensor’s electronic functions and is considered the core of the device. The processing in China is considered simple assembly and consists only of wire bonding and encapsulation. The completed die has the ability to sense pressure when it leaves the United Kingdom and is unchanged when it enters China.
Ruling Date: Aug. 22, 2025

N351893: The tariff classification and country of origin of a power bank

HTS: 8507.60.0020, 9903.01.24; 9903.01.25; 9903.88.15, 3.4% + 20% + 10% + 7.5%, “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Lithium-ion batteries: Other.”
Origin: China
Item: The merchandise under consideration is referred to as the Belkin Magnetic Power Bank with Qi2 5K and is described as a rechargeable lithium-ion power bank with a single USB-C input/output port and a 5,000 mAh capacity. The subject power bank is assembled in Vietnam using Chinese and Vietnamese components.
Reason: The assembly operations that occur in Vietnam do not result in a substantial transformation. There is no change in the name, use, or character of the battery cells after the assembly process occurs.
Ruling Date: Aug. 22, 2025

N351932: The classification, origin, marking, and eligibility under subheading 9802.00.5060 on a ring

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: A ring constructed of white gold set with either natural or lab produced diamonds. The ring is cast in the U.S. and finished in 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 white gold castings.
Ruling Date: Aug. 22, 2025

N351979: The country of origin of Cationic Guar Gum

Origin: India and U.S.
Item: The product is a cationic guar polymer obtained specifically from guar hydroxypropyltrimonium chloride. Due to a temporary shortage of raw material, the company is considering supplementing its U.S. production with identical N-Hance 3196 material produced by a qualified supplier in India. The Indian-origin product is chemically and functionally identical to the U.S.-origin version. The proposed operation involves blending the two materials at the company’s facility in Texas. This blending process will not result in any chemical reaction, transformation, or further processing; it is a simple commingling of like materials. Following blending, the finished product will be packaged and distributed in the United States.
Reason: The blending of Indian-origin and U.S.-origin N-Hance 3196 does not result in a commercially distinguishable product, therefore it does not constitute a substantial transformation.
Ruling Date: Aug. 22, 2025

N351989: 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: The jewelry at issue consists of platinum rings set with diamonds, 14K gold pendants set with diamonds, 14K gold earrings set with diamonds, 14K gold rings set with diamonds, and 14K gold bracelets with diamonds. The jewelry is cast in the U.S. and finished in the Philippines and Hong Kong.
Reason: The casting of the jewelry 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: Aug. 22, 2025

N352005: The tariff classification of knitted and woven blankets from China

HTS: (Items 2 and 5) 6301.40.0010, 9903.01.24, 9903.01.25, 8.5% + 20% + 10%, “Blankets and traveling rugs: Blankets (other than electric blankets) and traveling rugs, of synthetic fibers…Woven.” (Items 1, 3 and 4) 6301.40.0020, 9903.01.24, 9903.01.25, 8.5% + 20% + 10%, “Blankets and traveling rugs: Blankets (other than electric blankets) and traveling rugs, of synthetic fibers: Other.”
Item: Item 1 is a blanket made from a single layer of 100% polyester fleece knit pile fabric. The fabric is knit in a striped pattern. Item 2, described as a “Cuddly Blanket with Fringes,” is a blanket made from 100% polyester woven fabric that is brushed on both sides. The fabric is yarn dyed and woven in a plaid design. Item 3, described as a “Fleece Blanket with Loop,” is a blanket made from 100% polyester fleece knit pile fabric. Item 4, described as a “Cuddly Blanket,” is a blanket made from 100% polyester knit pile fabric dyed a solid orange bronze color. Item 5, described as a “Braided Blanket,” is a blanket made from 100% polyester woven fabric. The fabric is a solid gray color and features a woven checkerboard pattern.
Reason: N/A
Ruling Date: Aug. 22, 2025