The following final revocations and modifications of U.S. Customs and Border Protection rulings are included in the Sept. 30, 2020, Customs Bulletin and Decisions. These changes will be effective with respect to goods entered or withdrawn from warehouse for consumption on or after Nov. 30.

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

Alloy Steel Pipes

CBP is reclassifying alloy steel pipes principally used for power, refinery, heater, oil and gas, and paper and pulp applications as heat-resisting steel tubes and pipes suitable for use in boilers, superheaters, etc., under HTSUS 7304.59.2030 (duty-free) rather than as other tubes and pipes suitable for use in boilers, superheaters, etc., broken out by wall diameter under HTSUS 7304.59.2055, 7304.59.2060, and 7304.59.2070. CBP explains that the properties of these pipes indicate that they are actually, practically, and commercially fit for use in boilers, etc., and that even if they are not chiefly used in that way there is more than evidence of a casual, incidental, exceptional, or possible use. Ruling HQ H305822 will revoke rulings NY N303737 and NY N303738 to reflect this change.

Insulated Bags

CBP is reclassifying insulated pizza, grocery, and food delivery bags as insulated food or beverage bags with outer surface of textile materials under HTSUS 4202.92.08 (7 percent duty) rather than as other made-up articles under HTSUS 6307.90.98 (7 percent duty) or as plastic articles for the conveyance or packing of goods under HTSUS 3923.29.00 (3 percent duty) or HTSUS 3923.10.90 (3 percent duty). Ruling HQ H304836 will revoke rulings HQ967177, NY N020627, NY N243289, NY N261656, and NY N260407 to reflect this change. CBP explains that these rulings were issued before a 2003 change to the language of heading 4202 to specifically include insulated food or beverage bags.


CBP is reclassifying a mineral oil-based lubricant containing zinc and silica additives as greases containing not over ten percent by weight of salts or fatty acids of animal or vegetable origin under HTSUS 2710.19.3500 (5.8 percent duty) rather than as other lubricating grease under HTSUS 2710.19.4000 (1.3 cents/kg + 5.7 percent duty). CBP explains that the silica is entirely based on mineral oil and as such does not contain any salts or fatty acids of animal or plant origin. Ruling HQ H289346 will modify ruling NY N237898 to reflect this change.

Nonwoven Wipes

CBP is reclassifying nonwoven wipes for people and pets as other nonwovens impregnated with soap or detergent under HTSUS 3401.11.50 (duty-free) or HTSUS 3401.19.00 (duty-free), respectively. CBP had previously classified these items as other nonwovens under HTSUS 3401.19.00, other liquids or creams for washing the skin under HTSUS 3401.30.50 (duty-free), washing preparations under HTSUS 3402.20.5100 (duty-free), or aromatic organic surface-active agents under HTSUS 3402.12.1000 (4 percent duty). CBP explains that these wipes contain a detergent or other cleansing agent and are therefore not classifiable under heading 3402.

Ruling HQ H303126 will revoke rulings NY N301154, NY N300856, NY N303558, NY N290033, NY J89299, NY J87912, NY N236829, NY J87145, NY F88830, NY 810044, and NY N242165 and modify ruling NY N285765 to reflect this change.

Reversible Comforters

CBP has issued ruling HQ H309368 to revoke ruling NY N306605, in which it determined that the country of origin of reversible comforters is India. In that ruling CBP applied 19 CFR 102.21(e)(2)(i), which states that the county of origin is where the fabric comprising the good was both dyed and printed. However, CBP now finds that this provision is not applicable because the fabric comprising one side of the subject comforters is dyed while the fabric comprising the reverse side is printed, making the dyeing and printing mutually exclusive processes. CBP has instead determined under 19 CFR 102.21(c)(2) and (e)(2)(ii) that the country of origin is China, where the fabric comprising the comforters was formed by a fabric-making process.

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