Which rulings did CBP issue in May 2026?

Zircon imported by nonresident importer must use computed value, not transaction value

Iluka Resources plans to import zircon from Australia as both exporter and nonresident importer of record, holding title after importation and selling to U.S. customers later without a pre-import sale. CBP ruled that no bona fide sale for exportation exists, so transaction value cannot apply, and no identical or similar merchandise sales exist either. CBP held the zircon must be appraised under the computed value method of 19 U.S.C. 1401a(e), based on the producer's actual cost of materials, profit and general expenses, assists, and packing costs, using commercial accounts kept under Australian GAAP.

Who it matters to: This ruling matters to nonresident importers who retain title to goods after entry and sell them later in the U.S., since it confirms they must use computed value appraisement and document actual production costs rather than relying on transaction value.

CBP subject: Appraisement of Zircon from Australia; Computed Value Method

Stark Varg electric motorcycles from Mexico qualify for USMCA treatment

Stark Future USA asked CBP whether its Stark Varg MX/EX electric off-road motorcycle, classified under subheading 8711.60.00, qualifies for USMCA preference and what its country of origin is for marking. CBP found the motorcycle did not meet the tariff shift or regional value content rules, but the nonoriginating heading 8714 components fell under the 10 percent de minimis threshold, so the motorcycle qualifies for USMCA preferential treatment. CBP also determined that because the foreign materials meet the applicable tariff shift under 19 C.F.R. 102.20, the country of origin for marking purposes is Mexico.

Who it matters to: Importers assembling motorcycles or similar goods in Mexico from multiple foreign-origin parts can use the USMCA de minimis rule to qualify for preference even when tariff shift and regional value content tests fail.

CBP subject: USMCA Eligibility; Country of Origin Marking; Electric Motorcycles

Titanium spinal fusion cage qualifies for duty-free treatment under 9817.00.96

Captiva Spine asked CBP whether its titanium alloy Expandable Lumbar Fusion Cage, implanted during spinal fusion surgery to treat degenerative disc disease, qualifies for duty-free treatment as an article for handicapped persons. CBP applied the Sigvaris factors and found the cage is specially designed for patients with degenerative disc disease, is used only after failed conservative treatment, and is installed only by orthopedic or neurosurgeons. CBP held the device is eligible for duty-free treatment under subheading 9817.00.96, HTSUS.

Who it matters to: Importers of spinal implant devices used to treat degenerative disc disease can look to this ruling as support for claiming duty-free treatment under 9817.00.96.

CBP subject: Applicability of Subheading 9817.00.96, HTSUS to Expandable Lumbar Fusion Cage

HTS 9817.00.96

Epoxy resins from South Korea: computed value method approved for Kumho P&B

Kumho P&B Chemicals imports bulk and bagged epoxy resins from South Korea and stores them in a U.S. warehouse before sale, so no sale exists at entry to support transaction value. CBP found that transaction value and transaction value of identical or similar merchandise could not apply, and approved the importer's election of computed value under 19 U.S.C. 1401a(e), based on product code specific production costs, profit and SG&A ratios from audited financial statements, and foreign inland freight charges. CBP said the importer must be ready to give CBP documentation supporting the computed value calculation for each shipment.

Who it matters to: Importers who bring in merchandise for warehouse storage before any sale occurs, with no transaction value available, can look to this ruling for how CBP will accept a computed value approach and what cost documentation it expects.

CBP subject: Dear Ms. Sugama This is in response to your October 9, 2025, request for a binding ruling, on PB” or “importer”) regarding the proper behalf of Kumho P&B Chemicals, Inc. (“K method of appraisement for prospective entries of bagged and bulk epoxy resins manufactured in South Korea. The importer has asked that certain information submitted in connection with this ruling be treated as confidential. Inasmuch as this request conforms to the 9 C.F.R. § 177.2(b)(7), the request for confidentiality is approved. The requirements of 1 information contained within brackets in this ruling or in the attachments to the ruling request, forwarded to our office, will not be released to the public and will be withheld from published version of this ruling. FACTS KPB is a non-resident importer and manufacturer that will be importing bulk and bagged epoxy resins into the United States. KPB produces five types of epoxy resins in liquid epoxy resins; (2) solid epoxy resins; (3) solution epoxy resins; South

Cordless leaf blowers assembled in Vietnam are Vietnamese origin, not subject to Section 301

CBP reviewed a protest on cordless leaf blowers with motor components sourced from China but assembled, wound, and finished in Vietnam. CBP found that the manufacturing operations in Vietnam, including stator and rotor subassembly, motor assembly, injection molding, wiring, and final assembly, substantially transformed the Chinese components. CBP granted the protest and determined the country of origin is Vietnam, so Section 301 duties do not apply.

Who it matters to: Importers of motors or motor driven products assembled abroad from Chinese parts should review whether their manufacturing steps meet the substantial transformation standard CBP applied here.

CBP subject: Application for Further Review of Protest No. 2704-22-160379; Country of Origin of Leaf Blowers; Section 301 Measures

Solotech's metal racks, dollies, and tile carts qualify as instruments of international traffic

Solotech U.S. Corporation asked CBP whether metal racks, dollies, and tile carts used to transport lighting and audiovisual equipment qualify as instruments of international traffic under 19 U.S.C. § 1332(a) and 19 C.F.R. § 10.41a(a)(1). CBP found the metal racks and tile carts qualify as substantial containers that are reusable and used in significant numbers in international traffic. CBP found the dollies do not hold cargo independently but qualify as accessories to instruments of international traffic because they are substantial, reusable, and used in significant numbers.

Who it matters to: Importers using similar reusable racks, dollies, or carts to transport equipment internationally can look to this ruling for how CBP evaluates entry-free and duty-free treatment as instruments of international traffic or their accessories.

CBP subject: Instruments of International Traffic; 19 U.S.C. § 1332(a); §§ 10.41a(a)(1), 10a(a)(2); Solotech U.S. Corporation; metal racks; dollies; tile carts.

AI Smart Glasses Marked Origin Vietnam or Taiwan, Not Subject to Section 301

CBP reviewed AI-enabled smart glasses assembled from components sourced in at least nine countries, with final assembly (FATP) occurring in China or Thailand. CBP determined that the main logic board and secondary logic board, produced through SiP and SMT processes in Vietnam or Taiwan, form the essence of the glasses and substantially transform the components into a new article. As a result, CBP ruled the country of origin for marking and Section 301 purposes is Vietnam or Taiwan, and the glasses are not subject to Section 301 duties.

Who it matters to: Importers of multi-component electronic wearables should note that CBP focuses on where the core circuit board assembly is manufactured, not where final assembly occurs, when determining origin and Section 301 exposure.

CBP subject: Country of origin marking of Smart Glasses; Section 301

PureWick urine collection catheters qualify for duty-free treatment under 9817.00.96

CR Bard Inc. protested the denial of duty-free treatment for its PureWick System, a noninvasive external catheter that uses suction to draw urine from incontinent users into a collection canister. CBP considered whether the product is specially designed for handicapped persons and whether it falls under exclusions for acute disability or therapeutic articles. CBP held that the PureWick catheters qualify for duty-free treatment under subheading 9817.00.96, HTSUS, because they are specially designed for people with chronic, severe incontinence and do not treat or cure the underlying condition.

Who it matters to: Importers of external catheter systems or similar incontinence management devices for chronic conditions may qualify for duty-free treatment under 9817.00.96 if the products are not marketed for minor leakage or acute conditions.

CBP subject: Application for Further Review of Protest No. 2604-26-100449; Applicability of Subheading 9817.00.96, HTSUS; PureWick™ Catheters

HTS 9817.00.96

Zevo Insect Trap Starter Kits get Mexico origin for Section 301 purposes

Procter & Gamble asked CBP to decide the country of origin of its Zevo Insect Trap Starter Kits, which combine a Chinese-origin LED board and other Chinese parts with a glue cartridge and body components made in Mexico. CBP found that the injection molding of the housing and exterior parts, and the final assembly, occur in Mexico, and that these Mexican operations substantially transform the Chinese components. CBP held that Mexico is the country of origin for Section 301 trade remedy purposes.

Who it matters to: Importers of assembled products with Chinese electronic components and Mexican-made housings and final assembly can use this ruling to assess whether Section 301 duties apply to their goods.

CBP subject: Internal Advice; Country of Origin; Section 301 Trade Remedies, Zevo Insect Trap Starter Kit

Foldable e-bikes assembled in Paraguay remain products of China

CBP reviewed a protest claiming Paraguay as the country of origin for foldable electric bicycles whose magnesium alloy frame components are die cast in China and then assembled with other parts in Paraguay. CBP found that the frame gives the bicycle its essential character, and that the assembly, finishing, and electronics insertion done in Paraguay are minor operations that do not substantially transform the Chinese frame components. CBP denied the protest and held that the country of origin of the foldable electric bicycle is China.

Who it matters to: Importers of e-bikes or similar frame based products assembled outside China should confirm whether frame processing abroad is substantial enough to change origin, since CBP treats the frame as the essential character of the finished bicycle.

CBP subject: Country of Origin of Electric Foldable Bicycles

CBP clears STIIIZY's redesigned vape cartridges from ITC exclusion order in Investigation No. 337-TA-1392

STIIIZY asked CBP to rule whether its redesigned vaping cartridges fall under a limited exclusion order the ITC issued in Investigation No. 337-TA-1392 against oil vaporizing devices that infringe certain PAX Labs patents. CBP found that STIIIZY met its burden to show the redesigned cartridges are not covered by the exclusion order. CBP noted it will issue a separate ruling on related components, such as the vaporizer battery, by June 12, 2026.

Who it matters to: Importers of vaping devices or components tied to ITC Investigation No. 337-TA-1392 should review this ruling to see how CBP treats redesigned products against the scope of a Section 337 exclusion order.

CBP subject: Ruling Request; U.S. International Trade Commission; Limited Exclusion Order; Investigation No. 337-TA-1392; Certain Oil Vaporizing Devices, Components Thereof, and Products Containing the Same

Finished leather from U.S. wet blue hides processed in Italy stays U.S. origin

Optima Leathers imports finished leather made from U.S. wet blue hides that are split, shaved, re-tanned, dyed, dried, and finished in Italy. CBP considered whether the Italian processing changes the country of origin for trade remedy purposes. CBP ruled that the Italian operations are cosmetic finishing steps and do not substantially transform the hides, so the finished leather remains a product of the United States.

Who it matters to: Importers of leather made from U.S. wet blue or crust hides that undergo tanning, dyeing, and finishing abroad should know CBP may still treat the finished leather as U.S. origin for trade remedy purposes.

CBP subject: Country of Origin; Finished Leather

CBP rejects transaction value and downward price adjustment for Corneliani USA suits

Corneliani USA imported men's suits from related Italian seller Corneliani SpA and later sought a downward value adjustment based on a 2023 transfer pricing analysis and a credit note. CBP found the transfer pricing study used comparable companies in unrelated industries, so it did not satisfy the circumstances of sale test, meaning transaction value was not an acceptable method of appraisement. CBP also held that even if transaction value applied, Corneliani USA failed to meet the criteria for post importation adjustments because its pricing policy was not in place before the entry and did not specify how adjustments are determined.

Who it matters to: Importers using transfer pricing studies to support related party transaction value or post importation price adjustments should ensure the study uses truly comparable companies and meets all documentation requirements before importation.

CBP subject: Internal Advice; Related Party Transaction; Transaction Value; Reconciliation of Transfer Prices

CBP approves 15-year depreciation method for reusable transport tanks

A biotechnology importer sought approval to appraise reusable transport tanks moved between related parties, without any sale, using an annual average net book value based on 15-year straight-line depreciation. CBP found that transaction value and other primary methods under 19 U.S.C. 1401a(b) through (e) were unavailable because the tanks are not sold. CBP ruled that the fallback method under 19 U.S.C. 1401a(f) applies, and the proposed 15-year straight-line depreciation of acquisition cost is a reasonable adjustment if applied according to GAAP.

Who it matters to: Importers who move owned or related-party reusable containers or equipment across borders without a sale can use a depreciation-based fallback valuation if it follows GAAP and approximates actual value at export.

CBP subject: Method of appraisement for reusable transport tanks

Aircraft engine parts under care contracts valued at full list price, no 85% discount

U.K.-shipped aircraft engine parts imported by a U.S. repair shop under customer care contracts are not bought in a bona fide sale, so transaction value is unavailable. CBP held they must be appraised using the transaction value of identical or similar parts sold at the full World List Price in time and materials repairs. CBP rejected an 85% commercial-level deduction and the computed value alternative.

Who it matters to: Importers using sell-back or reimbursement arrangements with foreign suppliers should note that CBP may value the goods at arm's length prices for identical goods, without discounts lacking price-list support.

CBP subject: Transaction Value; Transaction Value of Identical or Similar Merchandise; Imported Aircraft Engine Parts; No Sale

CBP approves first sale valuation for Country A auto parts through related middleman

An automaker subsidiary imports shaft assembly propellers and other components from a Country A manufacturer through a related middleman before the parts reach the U.S. importer. CBP considered whether the sale between the unrelated manufacturer and the middleman qualifies as a bona fide arm's length sale for export that can support first sale transaction value. CBP held that first sale appraisement may be used because the goods were clearly destined for the U.S., the manufacturer and middleman are unrelated, and the middleman took title and risk of loss as a genuine buyer and seller rather than as an agent.

Who it matters to: Importers using multi-tier supply chains with a middleman can rely on first sale valuation if they document that the middleman assumes title, risk of loss, and acts as a true buyer and seller, not an agent.

CBP subject: “First sale” appraisement; imported automotive parts

Brioni's post-import transfer price cuts rejected, entered value stands

Brioni America imported apparel and accessories from a related seller and later filed reconciliation entries claiming downward transfer price adjustments based on a 2021 transfer pricing study. CBP reviewed whether the price was fixed or determinable by an objective formula at importation and found the sale agreement and study did not meet CBP's five-factor test for a valid transfer pricing policy. CBP denied the protest and held that the originally declared transaction value could not be adjusted.

Who it matters to: Importers using post-importation transfer price adjustments must have a written, pre-import transfer pricing policy tied to IRS section 482 with specific adjustment methods and full supporting data, or CBP will keep the entered value.

CBP subject: Protest and Application for Further Review of Protest No. 2506-23-100695; Reconciliation of Transfer Prices

USB 3.0 7-Port Hub moves to 8471.80.10, not 8517.62

CBP reconsidered NY N294888, which classified a USB 3.0 7-Port Hub (UH700) made by TP-Link under subheading 8517.62 as transmission or reception apparatus. CBP found the hub only expands USB ports on a PC and does not actively transmit or receive data over a wired or wireless network, so it functions as a unit of an automatic data processing machine. CBP modified the ruling and classified the UH700 under subheading 8471.80.10, which covers control or adapter units of automatic data processing machines, carrying a free general duty rate.

Who it matters to: Importers of USB hubs and similar PC peripheral adapter devices should review their classification, since CBP treats them as ADP machine units under 8471.80.10 rather than network transmission apparatus under 8517.62.

CBP subject: Modification of New York Ruling Letter (NY) N294888; Tariff classification of a USB 3.0 7-Port Hub

HTS 8471.80.10

Lightfoot e-scooter origin changes from China to Taiwan for Section 301 purposes

CBP reconsidered the origin of the Lightfoot e-scooter, which is assembled in Taiwan from a Taiwanese frame, Chinese components including solar panels, and a German battery. CBP had originally ruled the solar panels were part of the frame and made the scooter a product of China under Section 301. After reviewing new evidence showing the solar panels are only glued to removable plastic side panels and not structurally part of the aluminum frame, CBP modified NY N344694 and found the frame from Taiwan gives the scooter its essential character, making Taiwan the country of origin.

Who it matters to: Importers of e-bikes and e-scooters with mixed-origin components should know CBP treats the frame as the essence of the product when determining origin for Section 301 trade remedies.

CBP subject: Modification of NY N344694; Country of origin of an e-scooter

CBP removes duty-free status for aluminum wheelchair ramps under 9817.00.96

CBP reviewed rulings on aluminum ramps imported by DiscountRamps.com, some marketed as wheelchair ramps, that previously qualified for duty-free treatment under subheading 9817.00.96, HTSUS as articles for the handicapped. CBP found the ramps lack features that distinguish them from ramps sold to the general public for uses like pet transport, moving, or construction, so they do not meet the standard for being specially designed for handicapped persons. CBP modified 19 prior rulings and held that these ramps are not eligible for duty-free treatment under subheading 9817.00.96.

Who it matters to: Importers of ramps or similar mobility aids that also serve general public uses should expect CBP to deny 9817.00.96 duty-free treatment unless the product has features specifically distinguishing it for handicapped use.

CBP subject: Articles for the Handicapped; Subheading 9817.00.96, HTSUS; Ramps; Modification of NY 857905, dated December 4, 1990; NY N307507, dated November 24, 2019; NY N307863, dated December 9, 2019; NY N309629, dated March 5, 2020; NY N309828, dated March 10, 2020; NY N310366, dated March 23, 2020; NY N310486, dated March 30, 2020; NY N310627, dated April 6, 2020; NY N310672, dated April 8, 2020; NY N310839, dated April 13, 2020; NY N310894, dated April 13, 2020; NY N310927, dated April 17, 2020; NY N310929, dated April 17, 2020; NY N318221, dated March 25, 2021; NY N320463, dated July 26, 2021; NY N331356, dated March 17, 2023; NY N331643, dated March 30, 2023; NY N332362, dated April 28, 2023; and NY N333795, dated July 27, 2023

Men's blue jeans from Vietnam appraised on retailer's price, not earlier sale

Jade Apparel imported men's blue jeans from Vietnam through a chain involving a Hong Kong intermediary, Invest Wisdom, and the manufacturer, Cheng Rui, ultimately sold to retailer State and Liberty. Jade argued CBP should use the earlier sale price between Cheng Rui and Invest Wisdom, or between Jade and Invest Wisdom, as the transaction value. CBP denied the protest, finding Jade did not provide a complete paper trail proving a bona fide sale at those earlier levels, so appraisement remains based on the price paid by State and Liberty.

Who it matters to: Importers using multi-tiered supply chains must keep complete, consistent purchase orders, invoices, and payment records to support using an earlier sale price for customs valuation.

CBP subject: Application for Further Review of Protest No. 460125138797; Jade Apparel; “First Sale” Appraisement; Multi-Tiered Transaction

Decommissioned OCS platform stays a coastwise point despite well abandonment

A company asked CBP whether foreign-flagged vessels could remove a decommissioned Outer Continental Shelf platform's topside modules, hull, and mooring system without violating the coastwise laws. CBP ruled that once permanently plugged, the well itself is no longer a coastwise point, but the platform remains a coastwise point because it stays attached to the seabed as a fixed structure. Moving the topside modules, mooring system, or anchors to a U.S. port on a non-coastwise-qualified vessel violates 46 U.S.C. 55102, and towing the topside barge ashore requires coastwise-qualified tugs under 46 U.S.C. 55111, but towing the hull to a pristine OCS reef site beyond U.S. territorial waters does not violate the coastwise laws.

Who it matters to: Companies decommissioning offshore platforms on the Outer Continental Shelf must use coastwise-qualified vessels to move platform components to U.S. ports, even after the associated well is permanently abandoned.

CBP subject: Coastwise Transportation; Outer Continental Shelf; Wells; Fixed Structure; 46 U.S.C. §§ 55102, 55111; 19 C.F.R. § 4.80.