Background

The following proposed revocations of U.S. Customs and Border Protection classification rulings are included in the June 25, 2025, Customs Bulletin and Decisions. Comments on these proposed changes are due by July 25.

For more information on how to seek or utilize classification and other rulings, please contact ST&R.

Dimmers

CBP is proposing to reclassify certain dimmers as boards for electric control under HTSUS 8537.10.91 (2.7 percent duty) rather than as radio remote control apparatus under HTSUS 8526.92.50 (4.9 percent duty). Rulings NY N250956 and NY N250985 would be revoked to reflect this change.

The items at issue use radio frequency to wirelessly activate the operations of other devices controlled by an automation system, such as by adjusting light levels in other rooms, turning on music, and locking the doors.

CBP explains that heading 8526 is inapplicable because, while the dimmers may receive radio signals, the control of the lighting circuit is achieved through electrical connections and not radio frequency. Instead the dimmers each incorporate a board equipped with multiple switches to open, close, and protect electrical circuits, and such switches would meet the terms of heading 8536.

Men’s Footwear

CBP is proposing to reclassify certain men’s footwear as sports footwear under HTSUS 6402.19.90 (9 percent duty) rather than as protective footwear under HTSUS 6402.91.5020 (37.5 percent duty). Ruling NY N336132 would be revoked to reflect this change.

The items at issue are two styles of closed toe/closed heel men’s winter boots that cover the ankle but not the knee. Both are similar in style and construction but differ in types of closure. The external surface area of the uppers are said to consist of 88.59 percent rubber/plastics and 11.41 percent textile material. The outer soles are gripped for traction and are compatible with crampons to assist the wearer in climbing or walking in icy environments. The boots are well insulated, water-resistant, and considered protective against cold. They do not incorporate metal toe caps.

CBP states that these boots are specially designed for a sporting activity (mountaineering and/or ice climbing) and are marketed for outdoor pursuits including glacier, arctic, and snowshoe expeditions. Moreover, they are not meant to be worn as an everyday wear or typical hiking boot. Second, the boots have a provision for the attachment of spikes, sprigs, cleats, stops, clips, bars, or the like in the form of a specially-designed indentation at the heel to support crampon attachment.

Blood Product

CBP is proposing to reclassify hemin as a blood fraction under HTSUS 3002.12.0090 (duty-free) rather than as other organic compounds under HTSUS 2492.00.50 (3.7 percent duty). Rulings NY F88418 and NY 866291 would be revoked to reflect this change.

The product at issue is an iron-containing porphyrin derived from red blood cells that is used for the treatment of acute porphyria. This condition occurs when chemical compounds produced by the body called porphyrins are not broken down effectively, which can cause symptoms such as light sensitivity, rashes, and abdominal pain or cramping. Hemin is obtained from red blood cells via an extraction and purification process.

CBP explains that hemin is classifiable in both heading 2942 and heading 3002. CBP therefore uses GRI 3(a) to determine classification in heading 3002 because it more specifically describes the product.

Copyright © 2025 Sandler, Travis & Rosenberg, P.A.; WorldTrade Interactive, Inc. All rights reserved.

Practice Areas

ST&R: International Trade Law & Policy

Since 1977, we have set the standard for international trade lawyers and consultants, providing comprehensive and effective customs, import and export services to clients worldwide.

View Our Services 

Close

Cookie Consent

We have updated our Privacy Policy relating to our use of cookies on our website and the sharing of information. By continuing to use our website or subscribe to our publications, you agree to the Privacy Policy and Terms & Conditions.