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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N322925: The tariff classification of a robotic vacuum cleaner from China
| HTS: 8508.11.0000, free “Vacuum cleaners, parts thereof: With a self-contained electric motor: Of a power not exceeding 1,500 W and having a dust bag or other receptacle capacity not exceeding 20 l." |
| Item: A vacuum cleaner that sucks-up debris with rolling brushes and side brushes, and then cleans the ground by washable mop. With the built AI camera and autopilot-capable sensor, the device can realize the cognition of more dimensions of family environment information, so that it knows exactly what to avoid and what to clean. The vacuum cleaner is packaged with a “OMNI Station”, power cord, dust bag, cleaning brush, multi-function cleaning tool, cleaning brush side brushes and washable mopping pads. The OMNI Station is designed for collecting the debris, cleaning and drying the mopping pads, and recharging the vacuum machine. |
| Reason: N/A |
| Ruling Date: Dec. 9, 2021 |
N322939: The tariff classification of a biometric scanning device from Germany
| HTS: 8543.70.9960, 2.6%, “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” |
| Item: A biometric scanning device. The primary components are an optics module and an electronics module. The device further incorporates a cooling module and a battery power supply. The aforementioned parts are enclosed within an outer plastic shell and mounted onto a plastic chassis base module. You state that the Orb is used to biometrically scan the face and iris of an individual to verify whether they are entitled to acquire certain forms of digital cryptocurrency. In use, the optic module captures biometric images of the iris and/or face of the user. This information is then processed by the embedded electronics module to generate a unique code associated with that individual. This code is then sent via WiFI, Bluetooth, or LTE network to the company’s server for verification that the individual is allowed to gain access to the desired cryptocurrency. |
| Reason: N/A |
| Ruling Date: Dec. 9, 2021 |
N323048: The tariff classification of 2-Ethylhexyl 4-aminobenzoate (CAS # 26218-04-2) from China
| HTS: 2922.49.3000, 6.5%, “Amino-acids, other than those containing more than one kind of oxygen function, and their esters; salts thereof: Other: Aromatic: Other: Other: Products described in additional U.S. note 3 to section VI.” |
| Item: 2-Ethylhexyl 4-aminobenzoate (CAS # 26218-04-2). It will be used as a chemical additive in cosmetics. |
| Reason: Cutting to size and simple assembly operations are considered minor manufacturing processes that don't constitute a substantial transformation. |
| Ruling Date: Dec. 9, 2021 |
N322848: The tariff classification of a beekeeper suit from Pakistan
| HTS: 6211.43.1010, 16%, "Other garments, women’s or girls’: Of man-made fibers, Coveralls, jumpsuits and similar apparel: Other: Women’s.” |
| Item: A unisex beekeeping suit with detachable hood. The body of the coverall is composed of three layers of fabric. The outer layers are constructed from 100% polyester mesh knit fabric. The middle layer is constructed from 65% polyester, 35% cotton woven fabric coated on both sides with a PVC foam. The beekeeper hood consists of a veil constructed from black woven mesh fabric in the front and white polyester/cotton fabric at the back. The beekeeper hood is attached to the coverall by a heavy-duty zipper and features a wide brim to keep the veil away from the face and spring steel band rings to keep the veil away from the head when the hood isn't in use. |
| Reason: The beekeeper suit is a composite good, however, neither the polyester/cotton knit fabric nor the polyester/cotton woven fabric coated on both sides with PVC foam, imparts the essential character to this composite good. As a result, Style VC-1101 shall be classified in accordance with GRI 3(c). When goods can't be classified by reference 3(a) or 3(b), they shall be classified under the heading which occurs last in numerical order. |
| Ruling Date: Dec. 8, 2021 |
N322752: The tariff classification of lint rollers and adhesive paper rolls from Japan
| HTS: 4811.41.1000, free, "Paper, paperboard, cellulose wadding and webs of cellulose fibers, coated, impregnated, covered, surface-colored, surface-decorated or printed, in rolls or rectangular (including square) sheets, of any size, other than goods of the kind described in heading 4803, 4809 or 4810: Gummed or adhesive paper and paperboard: Self-adhesive: In strips or rolls of a width exceeding 15cm or in rectangular (including square) sheets with one side exceeding 36cm and the other side exceeding 15cm in the unfolded state." |
| Item: Multipurpose pet lint rollers and refills to remove pet hair, dust, allergens, and dander. Once assembled, the rod and roller mechanism can't be disassembled. The roller is fitted with a removable roll of adhesive-coated paper. The paper roll is perforated at regular intervals to form 30 sheets, and the perforated edge of each sheet is printed with an orange stripe to make it easier to find and tear. |
| Reason: The rollers are sets consisting of multiple separate components and are classifiable in accordance with GRI 3(b). Items C7007 and C7008 constitute “goods put up in sets for retail sale”. The purpose of the item is lint, dust, or hair removal, which is accomplished by the adhesive paper roll. Therefore, we the adhesive paper roll imparts the essential character. |
| Ruling Date: Dec. 8, 2021 |
N322849: The tariff classification of gloves from Pakistan
| HTS: 4203.29.1800, 14%, "Articles of apparel and clothing accessories, of leather or of composition leather: Gloves, mittens and mitts: Other: Gloves of horsehide or cowhide (except calfskin) leather: Other: Other." |
| Item: A beekeeper’s glove with a 100% cow leather palm and back side. The gauntlet style glove features an extended cuff and sleeve, which reaches the upper arm where it's secured by an elasticized arm opening. The lower portion of the sleeve is made of 100% polyester knit mesh fabric and the upper portion is composed of 65% polyester, 35% cotton woven fabric. The glove also features a plastic hook and clasp. The glove is designed to protect the beekeeper from being stung by bees. |
| Reason: The essential character of the glove is imparted by the cow leather. |
| Ruling Date: Dec. 8, 2021 |
N322881: The tariff classification of a slap bracelet 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 polyester slap bracelet. The article consists of a flexible piece of plastic that wraps itself around the wrist when struck or snapped. The plastic is covered with polyester fabric, and it features a stuffed textile character face in the center of the bracelet. In your submission, you stated that the bracelet is available with six different characters: snowman, penguin, deer, Santa, elf, and dog with a Santa hat. |
| Reason: Note 11 to Chapter 71 that the expression “imitation jewelry” means any small articles of personal adornment, for example rings, bracelets, necklaces, brooches, earrings, pendants, pins, and the like – not incorporating precious metal or metal clad with precious metal, except as minor constituents. The slap bracelet falls within the meaning and exemplars of imitation jewelry and is provided for in Heading 7117. |
| Ruling Date: Dec. 8, 2021 |
N322888: The tariff classification of framed glass mirrors from China
| HTS: 7009.92.5090, 6.5%, "Glass mirrors…framed: over 929 square centimeters in reflecting area." |
| Item: Various styles of glass mirrors with wooden frames measuring from 36 inches - 47 inches wide by 36 - 47.75 inches high. After importation into the United States the glass mirrors will be attached to matching wooden bedroom dressers. The mirrors will be imported with metal mounting brackets and screws which will be used to attach the mirrors to the dressers in the United States. However, the dressers won't be imported with the mirrors. |
| Reason: Although the mirrors are intended to be attached to matching bedroom dressers, they are imported without the dressers. As imported, the merchandise is simply regarded as a mirror. The mirrors are clearly provided for eo nomine as mirrors in heading 7009. Therefore, heading 9403 isn't applicable to this merchandise. |
| Ruling Date: Dec. 8, 2021 |