Which rulings did CBP issue in January 2026?

Bronze shield for Desert Storm Memorial qualifies for duty-free entry, bond surety waived

A bronze and steel cast shield, valued at $1.1 million, is being imported for permanent installation as part of the National Desert Storm Memorial on the National Mall. CBP ruled the shield qualifies for duty-free entry under subheading 9812.00.40, HTSUS, as an article imported for erecting a public monument, provided the importer files the required declaration under 19 C.F.R. 10.49(a) and secures a bond covering potential future duties. CBP also granted a waiver of the surety on that bond, consistent with the Center Director's consent.

Who it matters to: This ruling matters to importers bringing in monument or memorial articles under 9812.00.40, since it confirms the declaration and bonding requirements needed to get duty-free treatment and a possible surety waiver.

CBP subject: National Desert Storm Memorial; 9812.00.40, HTSUS; U.S. Note 2 to Subchapter XII, Chapter 98, HTSUS

AR indoor exercise kiosk classified under HTS 9506.91.00

The ruling covers the DIDIM Kiosk, an augmented reality indoor exercise platform that uses LiDAR sensors, a projector and a PC to guide users through fitness games and brain training activities. CBP considered whether the device fell under Section XVI as an electronic device or under Chapter 95 as exercise equipment. CBP decided the DIDIM is classified under HTS subheading 9506.91.00, which covers articles and equipment for general physical exercise, gymnastics or athletics.

Who it matters to: Importers of AR or sensor based fitness kiosks that guide physical exercise should expect classification under HTS 9506.91.00 rather than as an electronic device of Section XVI.

CBP subject: Tariff classification of an indoor exercise platform utilizing augmented reality (AR) technology

HTS 9506.91.00

Chinese-origin windshields altered in the US qualify for TIB duty-free entry

Vitro planned to import automotive windshields from China under subheading 8708.29.5060, add primer, locator pins, lace molding, wiper ticks, and camera brackets, then export them to Canada. CBP ruled the windshields qualify for duty-free temporary importation under bond under subheading 9813.00.05, found the operations are alterations rather than a manufacture so damaged windshields need not be accounted for as waste, and determined the windshields leave in the same condition as imported, so they are not subject to duty or Section 301 duties upon export to Canada under USMCA.

Who it matters to: Importers using Temporary Importation under Bond for parts that undergo minor finishing before export to Canada or Mexico can rely on this ruling to assess TIB eligibility, waste accounting, and USMCA same-condition duty treatment.

CBP subject: Temporary Importation under Bond; Automotive Windshields; United States-Mexico- Canada Agreement (USMCA)

Subaru Sambar Van and Suzuki Every microvans belong in 8703, not 8704

An importer protested CBP's liquidation of a 1992 Subaru Sambar Van and a 1990 Suzuki Every microvan under heading 8704, which covers vehicles for transporting goods, rather than heading 8703 for vehicles transporting persons. CBP reviewed the vehicles' second row seats with permanent anchor points, lack of a barrier between passenger and cargo areas, side windows, sliding doors with windows, and comfort features like air conditioning and carpeting. CBP found both vehicles principally designed for the transport of persons and classified them under subheading 8703.21.00, granting the protest in part.

Who it matters to: Importers of Japanese-market microvans and similar multipurpose vehicles should review passenger-oriented features like seating, windows, and comfort amenities, since these can determine classification under 8703 rather than 8704.

CBP subject: Application for Further Review of Protest No. 1303-18-100126; Classification of the Subaru Sambar Van and Suzuki Every

HTS 8703.21.00

Dynaflex oral sleep apnea appliances denied duty-free 9817.00.96 treatment

Dynaflex requested a ruling on whether five custom mandibular advancement devices (Dorsal, Adjustable Herbst, Respire Blue+, Respire AT, and Respire Micro AT), used to treat mild-to-moderate obstructive sleep apnea and snoring, qualify for duty-free treatment under subheading 9817.00.96, HTSUS. CBP found that OSA qualifies as a physical handicap but ruled the devices are not specially designed or adapted for handicapped persons because they share physical characteristics with over-the-counter anti-snoring mouthpieces and are marketed for snoring as well as OSA. CBP held that all five Oral Appliance models do not qualify for subheading 9817.00.96, HTSUS treatment.

Who it matters to: Importers of mandibular advancement devices or similar oral appliances marketed for both OSA and snoring should not expect duty-free treatment under 9817.00.96 unless the devices are clearly distinguishable from general anti-snoring products.

CBP subject: Articles for the handicapped; Subheading 9817.00.96; Oral Appliances for Obstructive Sleep Apnea

Nassimi coated fabrics from Taiwan split across 5903.10, 3921.12 and 6001.92.00

Nassimi, LLC protested CBP's reclassification of thirty coated fabric styles from Taiwan under 5903.20.25 and claimed they were PVC-coated fabrics of 5903.10.20. CBP placed brushed PVC-coated styles in 5903.10.20 (Clutch and Glaze in 5903.10.10 or 5903.10.20), and unworked PVC-coated styles in 3921.12.11 or 3921.12.15. Four polyurethane-coated knitted pile styles went to 6001.92.00.

Who it matters to: This ruling matters to importers of plastic-coated fabrics because coating type, brushing or pile construction, and plastic weight share can move goods between Chapters 39, 59 and 60.

CBP subject: Application for Further Review of Protest No. 2704-20-145056; Tariff Classification of Certain Coated Fabrics

HTS 3921.12.11, 3921.12.15, 5903.10.10, 5903.10.20, 6001.92.00

Restroom dispenser assemblies classified as parts under 8424.90.90, air freshener covers stay in 3926.90.99

Cintas Corporation protested CBP's classification of restroom dispenser assemblies (inline auto drip, automatic and manual soap/sanitizer, and clean seat dispensers) and air freshener dispenser covers imported without refill bags, batteries, or refill bottles. CBP ruled the four dispenser assemblies are parts of mechanical dispensing appliances under subheading 8424.90.90, because they cannot function without the separately imported refill bags or bottles that contain the pump mechanism. CBP held the air freshener dispenser covers remain classified under subheading 3926.90.99 as other articles of plastics, finding they are not integral parts of a fan under heading 8414 even though designed solely for use with a specific air freshener dispenser.

Who it matters to: Importers of dispenser housings or device components imported without their functional refill or pump elements should review whether their goods qualify as parts under heading 8424 rather than as finished appliances or plastic articles.

CBP subject: Application for Further Review of Protest No. 5301-23-108958; Classification of Certain Restroom Dispenser Assemblies and Air Freshener Dispenser Covers

HTS 3926.90.99, 8424.90.90

Posha cooking robot is a product of China in all assembly scenarios

CBP reviewed the Posha autonomous cooking appliance (HTS 8516.60.40), assembled from mostly Chinese-origin parts with final production in Korea or China. CBP ruled the country of origin is China under all three production scenarios because the Chinese-origin components impart the cooking function, and simple assembly steps abroad do not substantially transform the good. CBP also found Posha eligible for UKFTA preferential tariff treatment only under the scenario where final production, including PCBA manufacture, occurs entirely in Korea before shipment to the United States.

Who it matters to: Importers of multi-component electronic appliances assembled across China and Korea should know that Chinese-origin subcomponents can dictate country of origin even when final assembly and UKFTA processing occur in Korea, and that any post-assembly processing in a third country like China can void UKFTA eligibility.

CBP subject: Country of Origin and UKFTA Eligibility of the Posha Autonomous Cooking Appliance

Flexitouch Plus power supplies denied 9817.00.96 duty-free status

Nextern Inc. protested classification of power supplies for the Flexitouch Plus lymphedema device, which were classified under subheading 8504.40.95 and hit with a 25 percent Section 301 duty. CBP denied the claim that the power supplies qualify for duty-free treatment under subheading 9817.00.96 as articles for the handicapped. CBP found the power supplies are not easily distinguishable from ordinary power adapters and that the Flexitouch Plus device itself is therapeutic rather than adaptive, so the protest was denied.

Who it matters to: Importers of power supplies or accessories used with therapeutic medical devices should know CBP may deny 9817.00.96 duty-free treatment if the components resemble generic parts and the underlying device treats or heals a condition rather than adapts to a handicap.

CBP subject: Application for Further Review of Protest No. 3501-25-103394; Articles for the Handicapped; Subheading 9817.00.96; Flexitouch Plus Power Supplies

HTS 9817.00.96

Starter assembly for engines gets Malaysia as country of origin

Everspark Industries asked CBP to determine the country of origin of a starter assembly made from parts sourced from Malaysia, Taiwan, China, and Thailand. CBP found that the key subassemblies, the armature, field coil, and solenoid switch, are produced in Malaysia and are the most expensive and functionally essential parts. CBP ruled that the 43 step assembly process in Malaysia substantially transforms the non-Malaysian components, making Malaysia the country of origin for duty purposes.

Who it matters to: Importers of automotive starter assemblies with multi-country components should review whether their key subassembly production and final assembly location matches this fact pattern before claiming Malaysia origin.

CBP subject: Country of Origin of a Starter Assembly

Steel transfer tanks for pickup trucks stay in heading 7309, not 8708 or 8609

CBP reviewed steel transfer tanks with a 100 gallon capacity that mount onto pickup truck beds for hauling non-flammable liquids like diesel fuel. The importer asked CBP to classify the tanks under heading 8708 as motor vehicle parts, but CBP found the tanks lack removable fittings needed for heading 8609 and are more specifically covered by heading 7309. CBP affirmed the earlier ruling and kept the tanks in subheading 7309.00.00, which carries a free general duty rate.

Who it matters to: Importers of steel tanks permanently mounted to vehicles should expect classification in heading 7309 rather than as vehicle parts or transport containers, unless the tanks have removable fittings for door to door transport.

CBP subject: Affirmation of NY N333141; Tariff classification of steel transfer tanks from Mexico

HTS 7309.00.00

Bimetal thermal switches from Japan stay classified as "other" switches, not snap-action

NGT Controls asked CBP to reconsider NY N352330 and classify its bimetal thermal switches from Japan under 8536.50.9040 as snap-action switches. CBP found the switches operate through heat causing a bimetal strip or disc to bend, not through force on a spring-loaded actuator like true snap-action switches. CBP denied the reconsideration request and affirmed classification under subheading 8536.50.9065.

Who it matters to: Importers of bimetal thermal switches used in appliances, HVAC systems, or industrial equipment should classify them under 8536.50.9065, not as snap-action switches, unless the device has a spring-loaded actuator.

CBP subject: Request for reconsideration of NY N352330; Classification of a bimetal switch from Japan

CBP splits ruling on unlicensed online import platform's services

CBP reviewed an unlicensed foreign online platform that connects importers to brokers, offers an OCR tool to pull entry data from shipping documents, and provides an AI tool that suggests HTSUS subheadings. CBP found that simply connecting importers to brokers is not customs business, but flagged that the platform's power of attorney process and chat function may violate broker confidentiality and power of attorney rules. CBP also found the OCR tool constitutes customs business, and said the AI classification tool is customs business only if it gives subheadings beyond the six digit level for merchandise tied to an actual or intended entry.

Who it matters to: Importers using online platforms for broker matching, data extraction, or AI classification should know which of these functions CBP treats as licensed customs business and which raise broker compliance issues.

CBP subject: Online platform; conducting customs business without a license.

Klipsch Bluetooth speakers with USB playback belong in 8519.81.41, not 8518.22.00

CBP reviewed a protest by Voxx International Corp. over two Klipsch Heritage Bluetooth speakers with USB-C ports that can play audio files from a USB drive. CBP had liquidated the entry under subheading 8518.22.00 as multiple loudspeakers in one enclosure, but the protestant argued the speakers are sound reproducing apparatus. CBP agreed, finding the USB port and microprocessor let the speakers read and play back audio files from semiconductor media, and classified them under subheading 8519.81.41, allowing the protest.

Who it matters to: Importers of Bluetooth or wireless speakers with USB ports that can read and play audio files from external storage should review whether their products belong in heading 8519 rather than 8518.

CBP subject: Application for Further Review of Protest No. 1401-25-108344; Tariff classification of certain Bluetooth Speakers

HTS 8519.81.41

OilCatch plastic oil-catching bucket from Canada falls under 3926.90.10

CBP reviewed an OilCatch product, a bucket-shaped tool made of TPU plastic with steel rivets, used to catch residual oil during filter changes. CBP classified the product under subheading 3926.90.10, HTSUS, as a plastic bucket because the TPU plastic body gives the product its essential character. CBP also found the country of origin for marking purposes is Canada, and the product qualifies for USMCA preferential tariff treatment because it is produced entirely in Canada from Canadian materials.

Who it matters to: Importers of composite plastic and metal products made entirely in Canada can use this ruling to see how CBP applies essential character and origin rules for classification, marking, and USMCA eligibility.

CBP subject: Tariff Classification; Country of Origin Marking; USMCA Eligibility of OilCatch Product

HTS 3926.90.10

Bearing shock mount from China classified in 4016.99.60, protest granted

The ruling involves a bearing shock mount from China made of a metal outer layer (bronze or naval brass) bonded to an elastomer inner layer of hydrogenated nitrile butadiene rubber. CBP had liquidated the merchandise under heading 8483 as a part of bearing housings, but the importer protested, arguing for classification under heading 4016. CBP found the rubber inner layer gives the product its essential character and classified it under subheading 4016.99.60, HTSUS, granting the protest.

Who it matters to: Importers of composite metal and rubber components used with bearings should review this ruling to see if the item qualifies as vulcanized rubber under 4016 rather than as a machinery part under 8483.

CBP subject: Application for Further Review of Protest No. 4197-24-107768; Classification of a Bearing Shock Mount

HTS 4016.99.60

Micro Truk vehicles reclassified from works trucks to 8704.31.01 goods vehicles

CBP reconsidered the classification of Metro Motors' "Micro Truk" models 1010 and 1020, small utility vehicles with a two-person cab and rear cargo bed. Two prior rulings had classified them as works trucks under heading 8709, but CBP now finds they do not operate only in factories, warehouses, dock areas or airports and instead share features with road going goods vehicles. CBP revoked the earlier rulings and classified the Micro Truks under subheading 8704.31.01, which covers motor vehicles for the transport of goods with a spark ignition engine and a gross vehicle weight not exceeding 5 metric tons.

Who it matters to: Importers of small utility or work style vehicles marketed for landscaping, security, or similar non industrial uses should review whether their products still qualify as works trucks under heading 8709 or fall under heading 8704.

CBP subject: Revocation of HQ 965246 and HQ 964598; Tariff classification of certain vehicles for the transportation of goods

HTS 8704.31.01