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 were submitted with your ruling request letter.
The merchandise under consideration is identified as five LED modules for use in automotive applications, i.e., turn signal lamps. The LED modules will be further manufactured into the finished automotive lamp assembly after importation.
You describe the LED Modules as follows:
P552 MCA MY18 TURN RH BU 165 and P552 MCA MY18 TURN LH BU 165 - each item has eight LEDs, a printed circuit board, a connector, a capacitor and a heat sink. The LEDs illuminate when connected to the power converter/driver in the tail light housing.
P552 FRONT TURN w/SS BU 30 - has four LEDs, a printed circuit board, a connector, a plastic optical lens, an LED driver and a heat sink. This module includes the power converter/driver at the time of importation.
P558 MY17 TURN RH BU 160 - has six LEDs, a printed circuit board, a wire pigtail, a capacitor and a heat sink. The LEDs illuminate when connected to the power converter/driver in the tail light housing.
P558 MY17 TURN LH BU 160 - has six LEDs, a printed circuit board, a connector, a capacitor and a heat sink. The LEDs illuminate when connected to the 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, etc.), 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 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 TURN RH BU 165, P552 MCA MY18 TURN LH BU 165, P552 FRONT TURN w/SS BU 30, P558 MY17 TURN RH BU 160 and P558 MY17 TURN LH BU 160, 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