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:
Sign up for a free preview to unlock the rest of this article
If your job depends on informed compliance, you need International Trade Today. Delivered every business day and available any time online, only International Trade Today helps you stay current on the increasingly complex international trade regulatory environment.
N352105: The tariff classification of a specialized printed circuit board assembly for CPAP sleep therapy devices from Thailand
| HTS: 9019.20.0000, 9817.00.96, free, “[o]zone therapy, oxygen therapy, aerosol therapy, artificial respiration or other therapeutic respiration apparatus; parts and accessories thereof.” |
| Item: The item under consideration is a specialized printed circuit board assembly (PCBA), designed exclusively for the Philips DreamStation™ CPAP Sleep Therapy devices. The DreamStation devices provide continuous airway pressure (CPAP) and Bilevel Positive Airway Pressure (BiPAP) therapy to treat patients with obstructive sleep apnea. |
| Reason: The PCBA is a part of the DreamStation CPAP Sleep Therapy devices without which the devices cannot function and thus is eligible for duty-free treatment under subheading 9817.00.96, HTSUS. |
| Ruling Date: Aug. 29, 2025 |
N352111: The country of origin of shock absorbers
| Origin: Malaysia |
| Item: The articles under consideration are shock absorbers, which are components of suspension struts used in passenger vehicles. Their function is to accelerate and attenuate the vibration of the frame and body, and to improve the ride comfortability. Each shock absorber is composed of an inner tube, piston rod, and outer cylinder from Malaysia, as well as other minor components, and components of a valve assembly and piston assembly from China and Malaysia, which are assembled together in Malaysia. |
| Reason: The Chinese components of the valve and piston subassemblies lose their individual identities when combined with the components from Malaysia into the said sub-assemblies. In addition, the subassemblies are further combined with the Malaysian inner tube piston rod, and outer cylinder to create complete shock absorbers. Furthermore, the cost of the Malaysian components and labor amounts to 84 to 96 percent of the total cost of each absorber. |
| Ruling Date: Aug. 29, 2025 |
N352117: The tariff classification of duvet cover, dish towel, fitted sheet, beach towel and hand towel from Pakistan, India and China
| HTS: (Article #1) 6302.21.9050, 9903.02.51, 6.7% + 19%, “Bed linen, table linen, toilet linen and kitchen linen: Other bed linen printed: Of cotton: Other: Not napped… Other.” (Article #2) 6302.10.0008, 9903.02.51, 6% + 19%, “Bed linen, table linen, toilet linen and kitchen linen: Bed linen, knitted or crocheted: Of cotton: Sheets.” (Article #3) 6302.91.0035, 9903.01.84, 9903.02.26, 9.2% + 25% + 25%, “Bed linen, table linen, toilet linen and kitchen linen: Other: Of cotton: Other: Towels: Jacquard figured.” (Article #4 and Article #5) 6302.60.0020, 9903.01.24, 9903.01.25, 9903.02.51, 9903.88.15, 9.1% + 20% + 10% + 19% + 7.5%, “Bed linen, table linen, toilet linen and kitchen linen: Toilet linen and kitchen linen, of terry toweling or similar terry fabrics, of cotton: Towels: Other.” |
| Item: Article #1 is a duvet cover made from 100% cotton woven fabric. Article #2 is a fitted sheet made from 94% cotton and 6% elastane knit fabric. Article #3 is a set of dish towels made from 100% cotton woven fabric. Article # 4 is a towel made from 100% cotton woven fabric. Article #5 is a hand towel made from 100% cotton woven terry toweling fabric. |
| Reason: N/A |
| Ruling Date: Aug. 29, 2025 |
N352290: The country of origin of a CEFALY Enhanced Kit (SKU 10701)
| Origin: Taiwan |
| Item: The CEFALY Enhanced kit is intended for both the acute treatment and preventive therapy of migraines in adults. The CEFALY Enhanced (main device) generates a treatment signal that is sent to stimulate and desensitize the trigeminal nerve. The PCBAs of the main device are manufactured and programmed with firmware in Taiwan. |
| Reason: The functionality of the CEFALY Enhanced (main device) is driven by its main printed circuit board assembly (PCBA) and flex PCBA, which are manufactured in Taiwan. The assembly of the PCBAs and programming operations performed in Taiwan substantially transform the individual components into a product of Taiwan. |
| Ruling Date: Aug. 29, 2025 |
N352300: The country of origin of a CEFALY Connected Bundle VA Set (SKU 10811)
| Origin: Taiwan |
| Item: The CEFALY Connected Bundle VA Set is intended for the veteran market for both the acute treatment and preventive therapy of migraines in adults. The CEFALY Connected (main device) generates a treatment signal that is sent to stimulate and desensitize the trigeminal nerve. The printed circuit board assemblies (PCBAs) of the main device are manufactured and programmed with firmware in Taiwan. |
| Reason: The functionality of the CEFALY Connected (main device) is driven by its main PCBA and flex PCBA, which are manufactured in Taiwan. The assembly of the PCBAs and programming operations performed in Taiwan substantially transform the individual components into a product of Taiwan. |
| Ruling Date: Aug. 29, 2025 |
N352322: The tariff classification of lead acid batteries from Vietnam
| HTS: 8507.20.8041, 9903.02.69, 3.5% + 20%, “Electric storage batteries, including separators therefor, whether or not rectangular (including square); parts thereof: Other lead-acid storage batteries: Other: Other: 12 V batteries.” |
| Item: The products under consideration are AGM lead acid batteries which have a nominal voltage of 12 VDC but differ in overall dimensions and capacity, which range from 20 Ah to 75 Ah. The batteries will have either an F3, F4, F6, or F8 terminal post and each terminal post can fit either an M5 or M6 bolt. |
| Reason: The batteries are neither specially adapted nor designed exclusively for use with powered wheelchairs or powered mobility assistance scooters. |
| Ruling Date: Aug. 29, 2025 |
N352332: The country of origin of a CEFALY Connected Kit (SKU 10810)
| Origin: Taiwan |
| Item: The CEFALY Connected Kit is intended for both the acute treatment and preventive therapy of migraines in adults. The CEFALY Connected (main device) generates a treatment signal that is sent to stimulate and desensitize the trigeminal nerve. The printed circuit board assemblies (PCBAs) of the main device are manufactured and programmed with firmware in Taiwan. |
| Reason: The functionality of the CEFALY Connected (main device) is driven by its main PCBA and flex PCBA, which are manufactured in Taiwan. The assembly of the PCBAs and programming operations performed in Taiwan substantially transform the individual components into a product of Taiwan. |
| Ruling Date: Aug. 29, 2025 |
N352477: The country of origin of outdoor units
| Origin: China |
| Item: The products at issue are outdoor units, which consist of a chassis that encloses a compressor, a condenser, a motor, a fan, a printed circuit board (PCB) and valves. Each unit is designed to be paired with a separately imported indoor unit to produce a system that heats and cools spaces. With respect to origin, the final assembly of each unit occurs in Thailand using components from China and subassemblies produced in Thailand. |
| Reason: The components from Thailand and China are assembled to each other and the chassis (plates and panels) in Thailand to produce an outdoor unit. The steps that occur during the final assembly process are not complex, as they consist of processes such as screwing, bolting and welding operations. |
| Ruling Date: Aug. 29, 2025 |
N352490: The tariff classification of a fashion belt from China
| HTS: 6217.10.9510, 9903.01.24; 9903.01.25; 9903.88.15, 14.6% + 20% + 10% + 7.5%, "Other made up clothing accessories… Accessories: Other: Other, Of cotton." |
| Item: A fashion accessory belt. The belt is constructed from 100% cotton braided fabric. The belt features 2.5-inch tassels and is decorated with shells and plastic beads. |
| Reason: The essential character of the belt is imparted by the braided fabric. |
| Ruling Date: Aug. 29, 2025 |
N352518: The tariff classification of spectroscopy scanner from China
| HTS: 9027.50.4060, 9903.01.24; 9903.01.25; 9903.88.01, free + 20% + 10% + 25%, “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Other.” |
| Item: The item under consideration is described as the Prysm iO, which is a portable, rechargeable scanner that uses reflectance spectroscopy technology to measure carotenoid levels in the skin. |
| Reason: N/A |
| Ruling Date: Aug. 29, 2025 |