Executive Summary
This report summarizes the most recent CBP Headquarters (HQ) rulings published in the CROSS database. The database was last updated on October 29, 2025, with a total of 489 rulings modified in the last 30 days. Below are the three most recent HQ rulings with detailed summaries.
Recent CBP Rulings Summary Table
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Ruling Number
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Date
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Type
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Summary
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October 28, 2025
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Classification
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Printed Circuit Board Assemblies for Amusement Devices: The subject merchandise consists of four conjoined printed circuit board assemblies (PCBAs) designed for integration into commercial amusement devices such as pinball machines. These PCBAs function as a modular embedded data processing unit that monitors, collects, and transmits data from the host system to a centralized service. They collect real-time game metrics (scores, status, earnings, location) and transmit those metrics to a centralized cloud platform through an API. Holding: Classified under heading 9504, specifically subheading 9504.30.00, HTSUS (duty-free), which provides for video game consoles and machines, parts and accessories thereof. The PCBAs are not classified as “parts” but rather fall within the common and commercial meaning of the term “accessory” as they enhance the function and utility of video game consoles and machines by enabling remote score tracking, data analytics, and gaming options. Classification under heading 8471, 8473 and 8543, HTSUS, is precluded by operation of Note 1(p) to Section XVI.
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October 22, 2025
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Carriers / IIT
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Instruments of International Traffic – Racks and Reels: This ruling addresses whether transport units (metal racks and plastic reels) qualify as “instruments of international traffic” (IIT) within the meaning of 19 U.S.C. § 1322(a). The subject items are designed to transport electrode sheets through international traffic and be returned to China empty for refitting with electrode sheets and eventual reuse. The racks are made of Q235 Steel with dimensions of 1130mm x 731mm x 1175mm, and the reels are made of ABS thermoplastic with 650mm diameter. Approximately 27,000 subject racks and 27,000 reels are expected to enter into use for transporting electrodes used in the manufacture of energy storage systems at AESC-Smyrna’s U.S. plants. Holding: The subject racks and reels which have not yet formally entered the United States qualify for entry-free and duty-free treatment as IITs pursuant to 19 C.F.R. § 10.41a(a)(1). However, previous subject devices that underwent normal entry process and payment of applicable duties when originally imported qualify for duty-free treatment under Subheading 9803.00.0, HTSUS, not as IITs, but as “of foreign production and previously imported and duty paid” substantial holder. To qualify as an IIT, an article must be: (1) substantial, (2) suitable for and capable of repeated use, and (3) used in significant numbers in international traffic.
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October 17, 2025
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Classification
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Wheel and Tire Assemblies for Lawn and Garden Spreaders: The subject merchandise consists of wheel and tire assemblies used in the manufacture of tow-behind and walk-behind lawn and garden spreaders. These products consist of a welded steel hub and rim, a bearing or bushing that may be composed of steel or ABS plastic, and a tube-type rubber tire. The assemblies are imported from China. The specific wheel models include 45702Y, 45802G, 45825G, 48511G, 40880G, 40880Y, 40939G, and 45702G, with various dimensions ranging from 4 inches to 175mm nominal diameter. As lawn and garden spreaders are used to broadcast grass seed, fertilizer, and herbicide over a lawn or garden for purposes of improving or preparing the soil, they are provided for in heading 8432, HTSUS, as horticultural machinery for soil preparation or cultivation. Holding: By application of GRIs 1 and 6, the subject wheel and tire assemblies are classified under subheading 8432.90.00, HTSUS, which provides for “Agricultural, horticultural or forestry machinery for soil preparation or cultivation; lawn or sports ground rollers; parts thereof: Parts” (duty-free). The determination is consistent with NY N305062 (July 19, 2019) and NY N306401 (October 10, 2019).
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Key Observations
Classification Trends
The recent rulings demonstrate CBP’s continued focus on proper classification of specialized components and equipment. Notable trends include:
Technology Integration in Traditional Industries: HQ H348322 addresses the classification of PCBAs used in amusement devices, reflecting the increasing integration of IoT and data analytics technology into traditional arcade and gaming equipment. CBP determined that these data collection and transmission modules are properly classified as accessories to amusement devices rather than as standalone data processing equipment.
Instruments of International Traffic: HQ H348564 provides important guidance on the qualification requirements for IIT status under 19 U.S.C. § 1322(a). This ruling clarifies that reusable transport containers must meet three criteria: substantiality, suitability for repeated use, and use in significant numbers in international traffic. The ruling also distinguishes between merchandise that qualifies for IIT treatment upon initial entry versus merchandise that was previously entered duty-paid and may qualify for duty-free treatment under heading 9803 upon reimportation.
Parts Classification: HQ H348950 reaffirms CBP’s approach to classifying parts of agricultural and horticultural machinery. The ruling emphasizes that wheel and tire assemblies are integral components of lawn and garden spreaders and are properly classified as parts of the complete machines under heading 8432, HTSUS.
Impact for Importers
Amusement Device Importers: Companies importing PCBAs or similar electronic components for integration into amusement devices should note that these items may be classified as accessories under heading 9504 rather than as data processing equipment, resulting in duty-free treatment.
Energy Storage and Battery Manufacturers: Importers using reusable racks and reels for international shipments of components should review their current entry procedures. If these transport units meet the IIT criteria, they may qualify for entry-free and duty-free treatment, potentially reducing costs and administrative burden.
Agricultural Equipment Importers: Importers of parts for lawn and garden equipment should ensure proper classification under heading 8432 to benefit from duty-free treatment. The ruling provides useful precedent for similar wheel assemblies and other parts of horticultural machinery.
Recommendations for eezyImport Clients
Based on the recent rulings, eezyImport recommends the following actions for clients:
Review Current Classifications: Clients importing electronic components for amusement devices, reusable transport containers, or parts of agricultural/horticultural machinery should review their current tariff classifications in light of these recent rulings.
Evaluate IIT Eligibility: Companies using reusable racks, reels, or containers for international shipments should evaluate whether these items qualify for IIT treatment. Proper documentation of the containers’ characteristics (substantiality, durability, usage patterns) will be essential to support IIT claims.
Monitor Classification Developments: The increasing integration of technology into traditional products continues to present classification challenges. Companies should work with customs brokers and trade compliance professionals to ensure proper classification of hybrid products that combine traditional mechanical components with electronic data processing capabilities.
Maintain Accurate Records: As demonstrated by HQ H348564, the treatment of reusable containers may differ depending on whether they have been previously entered and duty-paid. Importers should maintain accurate records of prior entries to support claims for duty-free treatment under heading 9803 when applicable.
References
- U.S. Customs and Border Protection, CROSS Custom Rulings Online Search System, https://rulings.cbp.gov/home
- HQ H348322 (October 28, 2025) – Classification of PCBAs for Amusement Devices
- HQ H348564 (October 22, 2025) – IIT Status of Racks and Reels
- HQ H348950 (October 17, 2025) – Classification of Wheel and Tire Assemblies
- 19 U.S.C. § 1322(a) – Instruments of International Traffic
- 19 C.F.R. § 10.41a(a)(1) – IIT Regulations
- Harmonized Tariff Schedule of the United States (HTSUS)
Report Prepared By: eezyImport Customs Intelligence Team
For Questions or Additional Information: Contact your eezyImport representative
