CLA-2-85:OT:RR:NC:N4:410
Ms. Paula M. Connelly
Sandler, Travis & Rosenberg, P.A.
100 Trade Center, Suite G-700
Woburn, MA 01801
RE: The tariff classification of LED modules for use in automotive applications from China
Dear Ms. Connelly:
In your letter dated May 11, 2020, on behalf of your client OSRAM Continental, Inc., you requested a tariff classification ruling. Pictures and drawings are submitted with your ruling request letter.
The merchandise under consideration is four LED modules for use in automotive applications, i.e., sidemarkers and daytime running lamps. The LED modules will be further manufactured into the finished automotive lamp assembly after importation.
You describe the LED Modules as follows:
Sidemarker Modules:
P552 MCA MY18 SM BU 728 – consists of two LEDs, a printed circuit board and a connector. The LEDs will illuminate when connected to the power converter/driver in the headlamp.
P558 MY17 SM RH BU 60 – consists of four LEDs, a wire pigtail, a plastic optical lens, a resistor, a capacitor and a printed circuit board. The LEDs will illuminate when connected to the power converter/driver in the headlamp.
Daytime Runninglamp Modules:
P552 MCA MY18 DRL RH BU 8 – consists of 54 LEDs, a connector, a capacitor, a plastic carrier, a heatsink and a printed circuit board. The LEDs will illuminate when connected to the separate power converter/driver in the headlamp.
P558 MY17 DRL RH BU 24 - consists of 45 LEDs, a capacitor, a connector, a resistor, and a heatsink. The LEDs will illuminate when connected to the separate power converter/driver in the headlamp.
Based on the pictures and information that you have provided, the LED modules that have various electrical components, e.g., capacitors, heatsink, connectors, that when installed in a housing and connected to a power source, emit light. In essence, the subject merchandise is incorporated into a light fixture that is incorporated into a motor vehicle’s headlight to produce light. As such, each of these subject products is an unfinished LED lamp that has the essential character of the finished product. Therefore, the subject merchandise possesses the essential character of complete lamps and is classified by application of General Rule of Interpretation (GRI) 1 and GRI 2(a) under heading 8539, Harmonized Tariff Schedule of the United States (HTSUS), as lamps, HQ H298322 noted.
The applicable subheading for the LED Modules P552 MCA MY18 SM BU 728, P558 MY17 SM RH BU 60, P552 MCA MY18 DRL RH BU 8 and P558 MY17 DRL RH BU 24, will be 8539.50.0090, HTSUS, which provides for “Electrical filament or discharge lamps…; Light-emitting diode (LED) lamps; Other.” The rate of duty will be 2 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 https://hts.usitc.gov/current.
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 Michael Chen at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division