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CBP Ruling Changes: Cooked Shrimp, Women’s Sandals, Pipe Fittings

Thursday, June 06, 2019
Sandler, Travis & Rosenberg Trade Report

The following proposed or final revocations or modifications of U.S. Customs and Border Protection rulings are included in the May 29 2019, Customs Bulletin and Decisions. Comments on the proposed changes are due no later than June 28, and the final actions are effective for goods entered or withdrawn from warehouse for consumption on or after July 29.

Cooked Shrimp

CBP is proposing to modify ruling NY N281670 to find that shrimp exported from India is not substantially transformed by cooking in Guatemala and that the country of origin of the shrimp for marking purposes is therefore India and not Guatemala. CBP cites a 1989 ruling in which it found that the process of cooking does not substantially transform shrimp because it does not result in a change in its name, character, or use.

Women’s Sandals

CBP is reclassifying three styles of women’s sandals as footwear the uppers of which over 90 percent of the external surface area is plastics under HTSUS 6402.99.31 (6 percent duty) rather than as other footwear with open toes and open heels under HTSUS 6402.99.4960 (37.5 percent duty) or as other footwear valued over $6.50 but not over $12/pair under HTSUS 6402.99.8061 (90 cents/pair + 20 percent duty). CBP explains that the materials of the upper for these sandals consist of rubber or plastics because they are composed of textiles that are coated, covered, or laminated with an external layer or rubber/plastic that is visible to the naked eye. Ruling HQ H278605 will revoke ruling NY N270791 to reflect this change.

Pipe Fittings

CBP is reclassifying center sleeves and end rings for coupling assemblies as pipe fittings under HTSUS 7307.19.3085 (5.6 percent duty) rather than as other articles of iron or steel under HTSUS 7326.90.8588 (2.9 percent duty) or other cast articles of iron or steel under HTSUS 7325.99.10 (duty-free). CBP explains that the identity of the sleeve and end ring combinations is indelibly fixed as that of a coupling at the time of their entry and that there is no indication that either item is suitable for any other use. Ruling HQ H284443 will revoke rulings NY N270588 and NY N097562 to reflect this change.

For more information on how to seek or utilize classification or other rulings, please contact customs attorney Deb Stern at (305) 894-1007.

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