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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N351882: The tariff classification of surgical scrub brushes from China
| HTS: 9603.90.8050, 9903.01.24; 9903.01.25; 9903.88.15, 2.8% + 20% + 10% + 7.5%, “[b]rooms, brushes (including brushes constituting parts of machines, appliances or vehicles), hand-operated mechanical floor sweepers, not motorized, mops and feather dusters; prepared knots and tufts for broom or brush making; paint pads and rollers; squeegees (other than roller squeegees): [o]ther: [o]ther: [o]ther.” |
| Item: The four products under consideration are all scrub brushes used to clean hands in preparation for surgery. These brushes come in four versions: dry (no disinfectant added), 20 milliliters of povidone iodine added, 20 milliliters of chlorhexidine gluconate added, and 20 milliliters of para-chloro-meta-xylenol (PCMX) added. The boxes are intended to be placed next to the surgery preparation sink for use. |
| Reason: N/A |
| Ruling Date: Aug. 27, 2025 |
N351894: The tariff classification of steel toilet paper holder from Taiwan
| HTS: 7324.90.0000, 9903.81.90; 9903.02.60, free + 50% + 20%, “Sanitary ware and parts thereof, of iron or steel: Other, including parts.” |
| Item: The article under consideration is described as a Freestanding Toilet Paper Holder, which is made of 95% low-carbon steel and 5% zinc and it is available in chrome, satin nickel, matte black and brushed brass finishes. |
| Reason: N/A |
| Ruling Date: Aug. 27, 2025 |
N351904: The tariff classification and country of origin of automotive oil filters
| HTS: 8421.23.0000, 9903.01.24; 9903.01.25; 9903.88.03, 2.5% + 20% + 10% + 25%, “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for liquids: Oil or fuel filters for internal combustion engines.” |
| Origin: China |
| Item: The item under consideration is described as an automotive oil filter, which is designed for use in the lubrication system of internal combustion engines, specifically in passenger vehicles and light-duty trucks. The manufacturing process occurs in Malaysia and starts with the injection of the glue and the paper element assembly. |
| Reason: The manufacturing and assembly process performed in Malaysia is not considered complex. While numerous steps are needed to assemble the Chinese and Malaysian components, the core components, including the paper element assembly, housing assembly, and upper element assembly are not transformed by the simple assembly process in Malaysia. |
| Ruling Date: Aug. 27, 2025 |
N351922: The country of origin of a refrigerant recovery unit
| Origin: China |
| Item: The product at issue is a refrigerant recovery unit. The unit, which is a composite machine, is designed to push liquid refrigerant into an external recovery tank and is composed of an outer casing that primarily encloses a motor, a compressor, a condenser, a fan, and a filter. With respect to origin, the final assembly occurs in Thailand using components sourced from China and a motor produced in Thailand. |
| Reason: The final assembly operations, which occur in Thailand, don't result in a substantial transformation. The components are installed using processes that are rather simple. |
| Ruling Date: Aug. 27, 2025 |
N351999: The tariff classification and country of origin of wheel bearings
| HTS: 8482.10.5028, 9903.81.91; 9903.02.61, 9% + 50% + 19%, “Ball or roller bearings, and parts thereof: Ball bearings: Other: Angular contact bearings: Other.” |
| Origin: Thailand |
| Item: The products at issue are wheel bearings, which are designed to support axial and radial loads, consist of an outer ring, inner rings, and a double row of balls incorporated into cages. The bearings are used in wheel hub assemblies installed in sedans, sports utility vehicles, crossover utility vehicles, minivans and light trucks. The final assembly of the wheel bearings occurs in Thailand using components sourced from Thailand and China. Prior to the final assembly process, rings sourced from China undergo various processes in Thailand, in which the rings are transformed into races with precision raceways. |
| Reason: The final assembly processes that occur in Thailand would not entail the type of processing required to meet the substantial transformation test. The assembly of the ball bearing is rather simple. Inserting and pressing components does not substantially transform the Chinese components. Instead, it is the country of origin of the inner and outer races, which are the essence of anti-friction bearings. Here, the origin of the inner and the outer races with precision raceways is Thailand. |
| Ruling Date: Aug. 27, 2025 |
N352096: The tariff classification of a Geranium-2 Unmanned Aerial System (UAS) from Russia
| HTS: 8806.99.0000, 9903.01.29, 30%: “Unmanned aircraft: Other: Other.” |
| Item: The item under consideration has been identified as a Geranium-2, Unmanned Aerial System (UAS), which is the Russian version of the Shahed 136 UAS. The UAVs (jammed, downed, or captured) remain sufficiently intact for reverse-engineering and R&D by U.S. defense contractors in support of National Security. The UAV will be utilized within a controlled research and development setting, focusing on electromagnetic interference (EMI) testing to advance the capabilities of counter-UAV systems. |
| Reason: N/A |
| Ruling Date: Aug. 27, 2025 |
N352101: The country of origin of a telehandler
| Origin: Turkey |
| Item: The merchandise under consideration is identified as a telehandler, which is a self-propelled lifting and handling machine with a long telescoping boom. The subject telehandler is manufactured in Turkey using subassemblies and parts sourced from various countries. |
| Reason: The nature of the processing performed in Turkey is not simple. In addition to the final assembly occurring in Turkey, two of the major structural subassemblies (i.e., the frame assembly and the boom assembly) are manufactured from common metal forms (e.g., metal sheets, plates, and tubing) and transformed into integral subassemblies in Turkey. |
| Ruling Date: Aug. 27, 2025 |
N352102: The tariff classification of steel toilet paper holder from Taiwan
| HTS: 7324.90.0000, 9903.81.90; 9903.02.60, free + 50% + 20%, “Sanitary ware and parts thereof, of iron or steel: Other, including parts.” |
| Item: The article under consideration is described as a Toilet Tissue Holder with Storage, which is made of 96% low-carbon steel and 4% zinc and is available in chrome, satin nickel, and brushed brass finishes. The horizontal bar flips upward to store and remove the extra rolls of toilet paper. |
| Reason: N/A |
| Ruling Date: Aug. 27, 2025 |
N352128: The tariff classification of a biopsy site marker in an applicator system from Mexico
| HTS: 9018.90.8000, 9903.01.27, free, “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof: [o]ther instruments and appliances and parts and accessories thereof: [o]ther: [o]ther.” |
| Item: The Mammotome LumiMARK Biopsy Site Marker consists of an applicator device preloaded with a rose-shaped nitinol biopsy site marker, packaged in a sterile sealed pouch. The biopsy site marker is a small, self-expanding device made of nitinol, a biocompatible nickel-titanium alloy known for its shape memory and radiopacity. |
| Reason: N/A |
| Ruling Date: Aug. 27, 2025 |
N352172: The tariff classification of lancets, mobile lancets, and lancing device from an undisclosed country
| HTS: (Lancets) 9018.39.0050, 9817.00.96, free, “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences, including scintigraphic apparatus, other electro-medical apparatus and sight-testing instruments; parts and accessories thereof: [s]yringes, needles, catheters, cannulae and the like; parts and accessories thereof: [o]ther: [o]ther.” (Lancing Device and Mobile Lancets) 9018.90.8000, 9817.00.96, free, “[i]nstruments and appliances used in medical, surgical, dental or veterinary sciences … parts and accessories thereof: [o]ther instruments and appliances and parts and accessories thereof: [o]ther: [o]ther.” |
| Item: A lancet is a needle like article encased in a plastic holder with a plastic cap. They are designed for use with the WALG Lancing Device (WIC 935370), which is a spring-loaded device featuring nine adjustable depth settings and an auto-ejector that holds and ejects the lancet (sold separately) into the skin to painlessly extract a drop of blood (typically from a fingertip) for blood glucose testing. The WALG Mobile Lancets 30G 25S (WIC 935321) are single use, disposable, all-in-one lancets and lancing devices. The mobile lancet features an integrated push-button mechanism, eliminating the need for additional equipment. The lancets, lancing device, and mobile lancets are intended for use by individuals with diabetes. |
| Reason: The subject lancets, lancing device, and mobile lancets are designed to be used together to obtain a diabetic’s blood sample to be analyzed by a blood glucose monitoring device. They are crucial tools for individuals with diabetes, enabling them to monitor their blood sugar levels regularly. |
| Ruling Date: Aug. 27, 2025 |