The following proposed revocations or modifications of U.S. Customs and Border Protection rulings are included in the March 27, 2024, Customs Bulletin and Decisions. Comments on these proposed changes are due by April 26.

For more information on how to seek or utilize classification and other rulings, please contact attorney Deb Stern at (305) 894-1007 or via email. Click here to register for ST&R’s April 9 webinar on the basics of tariff classification.

Auto Component

CBP is proposing to reverse a determination regarding the country of origin of an absorber crashbox, a component of passenger vehicles placed between the bumper and side rails that is designed exclusively to prevent the spread of kinetic energy in the event of a collision, thus generating less damage to the vehicle structure.

These items are manufactured and assembled in Mexico with certain imported components from China. In ruling NY N326445 CBP determined that the country of origin of this item for marking purposes was Mexico because the applicable tariff shift requirement was met. However, CBP also determined that the Chinese components did not undergo substantial processing in Mexico and that the country of origin of the crashboxes for purposes of applying Section 301 tariffs was therefore China.

CBP is now proposing to modify its previous ruling to state that the country of origin of the crashboxes for Section 301 tariff purposes is Mexico. CBP explains that certain of the Chinese components underwent sufficient cutting and shaping in Mexico such that their form after processing was no longer the same.

Cargo Securing Device

CBP is proposing to reclassify a ratchet and pawl cargo securing device as a mechanical appliance with individual functions not specified elsewhere under HTSUS 8479.89.95 (2.5 percent duty) rather than as a winch under HTSUS 8425.39.0100 (duty-free). Ruling NY N262442 would be revoked to reflect this change.

The product at issue is designed to be used with a two-inch woven polyester webbing to secure cargo and prevent it from shifting. It basically consists of a frame containing toothed ratchet wheels mounted at the sides of a slotted drum, spring-loaded pawls, and a lever handle that the user pumps back and forth to tighten the webbing that has been threaded through the frame.

CBP states while this product does provide mechanical advantage and is thus distinguishable from simple hardware like D-rings, it is not a winch because it does not have a separate stand-alone drum or a handle or crank.

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