This report provides a comprehensive overview of recent U.S. Customs and Border Protection (CBP) rulings and decisions from January 2026. The information was gathered from the CROSS (Custom Rulings Online Search System) database and official CBP publications.
Key Statistics:
- Total Rulings in Last 30 Days: 217 rulings
- HQ (Headquarters) Rulings: 7 rulings
- NY (New York) Rulings: 210 rulings
- Database Last Updated: January 27, 2026
- Most Recent Ruling Date: January 29, 2026
Report Focus: This report highlights the most significant HQ rulings and selected notable NY rulings that may impact import/export operations, with emphasis on classification changes, country of origin determinations, and trade remedy applications.
Recent CBP Rulings Summary Table
| Ruling/Case Number | Date | Type | Summary (3 Lines) |
|---|---|---|---|
| HQ H351314 | January 20, 2026 | Classification | Steel Transfer Tanks Reclassification: CBP affirmed the classification of steel transfer tanks under HTSUS 7309.00.0090. The ruling clarifies they are not parts of motor vehicles under 8708, reinforcing that specific provisions prevail over general ones. |
| HQ H354469 | January 16, 2026 | Classification | Bimetal Switch Classification: CBP affirmed the classification of bimetal thermal switches as “other switches” under HTSUS 8536.50.9065. The ruling distinguishes them from “snap-action” switches due to the lack of a spring-loaded mechanism. This emphasizes the need for precise technical definitions in classification. |
| NY N357229 | January 16, 2026 | Classification | Automotive Radiators Classification: CBP classified automotive radiators under HTSUS 8708.91.5000. USMCA eligibility will be determined in a future ruling. This shows a multi-step process for complex goods. |
| HQ H342833 | December 19, 2025 | Origin | Electronically Commutated Motor Origin: CBP determined the country of origin for an Electronically Commutated Motor to be Thailand. The ruling was based on a substantial transformation analysis, where the Thai manufacturing and assembly operations were found to be sufficiently complex. This decision provides guidance on origin for products with components from multiple countries. |
| HQ H298116 | November 4, 2025 | Classification | Drum-Type Cleaning Machine Classification: CBP denied a protest and affirmed the classification of a drum-type cleaning machine under HTSUS 8479.89.98. The ruling clarifies that the machine’s primary function is cleaning, not metal treatment. This highlights the importance of a product’s principal function in classification. |
| HQ H346389 | October 28, 2025 | Classification | Vehicle Storage Systems Classification: CBP is reviewing the classification of vehicle storage systems, currently classified under heading 4202. The protest argues for classification as textile articles or vehicle parts. This ruling will provide clarity on the classification of multi-functional automotive accessories. |
| HQ H295580 | July 15, 2025 | Classification | Mobile Shredder Trucks Classification: CBP is reviewing the classification of mobile shredder trucks. The key issue is whether they should be classified as motor vehicles (8704) or as machinery. This ruling will have significant implications for importers of specialized commercial vehicles. |
| NY N357243 | January 16, 2026 | Classification | Lunar Regolith Simulants Classification: CBP classified lunar regolith simulants as “pebbles, gravel, broken or crushed stone” under HTSUS 2517.49.0000 (duty-free). This ruling demonstrates how novel materials are classified by analogy to existing tariff provisions. The classification highlights material composition as the primary factor. |
| NY N357277 | January 16, 2026 | Origin | Control Arms Country of Origin: CBP determined the country of origin for control arms to be Vietnam for marking and trade remedy purposes. The ruling was based on a substantial transformation analysis, where assembly in Vietnam with over 64% Vietnamese content and labor was key. This provides a clear example of the substantial transformation test. |
Key Themes and Trends
Country of Origin and Substantial Transformation
A recurring theme in the January 2026 rulings is the critical importance of the substantial transformation test in determining country of origin. This was particularly evident in:
- HQ H342833 (Electronically Commutated Motor): This ruling provides a detailed analysis of what constitutes a substantial transformation for a product with components from multiple countries. The decision emphasizes that the complexity and nature of the assembly process, not just the origin of the components, are key factors.
- N357277 (Control Arms): This ruling offers a clear example of how CBP applies the substantial transformation test in the context of assembly operations. The high percentage of Vietnamese content and labor was a decisive factor in determining the country of origin.
These rulings indicate that CBP is closely scrutinizing supply chains and manufacturing processes to ensure that the country of origin accurately reflects where the most significant and complex work is performed.
Classification of Multi-Function and Novel Products
Several rulings addressed the challenges of classifying products that have multiple functions or are new to the market:
- HQ H298116 (Drum-Type Cleaning Machine): This ruling highlights the importance of identifying a product’s principal function for classification purposes. Even though the machine had metal treatment capabilities, its primary function was determined to be cleaning, which led to its classification under a different heading.
- N357243 (Lunar Regolith Simulants): This case demonstrates how CBP classifies novel materials by drawing analogies to existing tariff provisions. The classification of lunar regolith simulant as a type of stone underscores the importance of material composition in the absence of a specific tariff provision.
- HQ H346389 (Vehicle Storage Systems): The ongoing review of this case indicates the complexities of classifying multi-functional products that could potentially fall under several headings. The final decision will provide important guidance for importers of similar automotive accessories.
These rulings underscore the need for importers to have a thorough understanding of their products’ technical specifications and primary functions to ensure correct classification.
References
- U.S. Customs and Border Protection. “CROSS Custom Rulings Online Search System.” https://rulings.cbp.gov/
- U.S. Customs and Border Protection. “HQ H351314: Affirmation of NY N333141; Tariff classification of steel transfer tanks from Mexico.” January 20, 2026. https://rulings.cbp.gov/docs/hq/2026/h351314
- U.S. Customs and Border Protection. “HQ H354469: Request for reconsideration of NY N352330; Classification of a bimetal switch from Japan.” January 16, 2026. https://rulings.cbp.gov/docs/hq/2026/h354469
- U.S. Customs and Border Protection. “N357229: The tariff classification, country of origin for marking and applying trade remedies under Section 301 or additional duties, and eligibility of the United States-Mexico-Canada Agreement (USMCA) of radiators from Canada.” January 16, 2026. https://rulings.cbp.gov/docs/ny/2026/n357229
- U.S. Customs and Border Protection. “HQ H342833: Country of Origin of an Electronically Commutated Motor; Section 301 Trade Remedy.” December 19, 2025. https://rulings.cbp.gov/docs/hq/2025/h342833
- U.S. Customs and Border Protection. “HQ H298116: Request for Further Review of Protest Number 4102-17-100682; Classification of a Drum-Type Cleaning Machine.” November 4, 2025. https://rulings.cbp.gov/docs/hq/2025/h298116
- U.S. Customs and Border Protection. “HQ H346389: Protest and Application for Further Review No. 2704-25-171943; Classification of certain vehicle storage systems.” October 28, 2025. https://rulings.cbp.gov/docs/hq/2025/h346389
- U.S. Customs and Border Protection. “HQ H295580: Application for Further Review of Protest No. 3802-18-100009; Classification of Certain Mobile Shredder Trucks.” July 15, 2025. https://rulings.cbp.gov/docs/hq/2025/h295580
- U.S. Customs and Border Protection. “N357243: The tariff classification of lunar regolith simulants from Spain.” January 16, 2026. https://rulings.cbp.gov/docs/ny/2026/n357243
- U.S. Customs and Border Protection. “N357277: The country of origin of control arms.” January 16, 2026. https://rulings.cbp.gov/docs/ny/2026/n357277
