CLA-2-94:OT:RR:NC:N4:110
Ms. Nithya Nagarajan, Esq.
Law Office of Nithya Nagarajan, LLC
9101 Friars Road
Bethesda, MD 20817
RE: The tariff classification of parts for lighting fixtures from China, Korea and Taiwan
Dear Ms. Nagarajan:
In your letter dated September 4, 2015, on behalf of your client Intense Lighting, LLC, you requested a tariff classification ruling.
The articles under consideration are glass lenses, metal screws and plastic parts that will be used as component parts in the assembly of LED lighting fixture Model MBLXXXXX.
Item 1, part number PFL45-2, is described as Glass Lenses. These are convex shaped lenses made of glass with a rating of tempered soda lime glass. The principle use of the glass lenses is to aim and direct light in the completed lighting fixture. The glass is typically used in tracklights or recessed luminaires. You have indicated that the lenses are specifically designed only for the LED lighting fixture, Model MBLXXXXX.
Item 2, part number 91420A120, is described as a zinc-plated steel Phillips flat head screw. It measures M3-0.5 X 10 and is fully threaded along its length. You indicate that these screws are used to assemble a completed light fixture.
Item 3, part number 21001, is described as Plastic Parts comprised of clip shaped plastic elements. The plastic clips are designed to snap into the casing of a completed light fixture to hold the finished product together and to prevent the light fixture from inadvertently separating into component parts. The plastic clips are made of polycarbonate (Panlite) LV-2250. The clips are compounded with fluorine powder to improve friction and abrasion resistance. The principal use of the plastic clips is to lock the track luminaire into the rack rail section of the completed lighting fixture. You have indicated that the plastic parts cannot be independently used or utilized outside of its use as a component of a finished lighting fixture.
The applicable subheading for part number PFL45-2, Glass Lenses, will be 9405.91.6080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Lamps and lighting fittings...and parts thereof not elsewhere specified or included: Parts: Of glass: Other: Other." The general rate of duty will be 4.5 percent ad valorem.
The applicable subheading for part number 91420A120, zinc-plated steel Phillips flat head screw, will be 7318.15.6080, HTSUS, which provides for screws, bolts, nuts, coach screws, screw hooks, rivets, cotters, cotter pins, washers (including spring washers) and similar articles, of iron or steel: threaded articles: other screws and bolts, whether or not with their nuts or washers: other: having shanks or threads with a diameter of less than 6 mm: other: other. The duty rate will be 6.2 percent ad valorem.
The applicable subheading for part number 21001, Plastic Parts, will be 9405.92.0000, HTSUS, which provides for “Lamps and lighting fittings…and parts thereof not elsewhere specified or included: Parts: Of plastics.” The general rate of duty will be 3.7 percent ad valorem.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Hope Abada at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division