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 15, 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 three LED modules for use in automotive applications, i.e., reverse and front parking lamps. The LED modules will be further manufactured into the finished automotive lamp assembly after importation.
You describe the LED modules as follows:
The reverse lamp LED modules are identified as TESLA M3 SAE/ECE LG Reverse LH BU180 and TESLA M3 SAE/ECE LG Reverse RH BU180. Each LED module has four LEDs, a printed circuit board, a connector and a heat sink. The LEDs will illuminate when connected to power converter/driver in the side signal lamp.
The front parking LED module is identified as P552 FRONT PRK TRN GEN2 BU168. It has an LED, a printed circuit board, a wire pigtail, a plastic light pipe coupler and a heat sink. The LED will illuminate when connected to the power converter/driver in the headlamp. The module will illuminate at full intensity in the “turn” function and will illuminate at a lower intensity in the “park” function.
Based on the pictures and information that you have provided, the LED modules that have various electrical components, e.g., capacitors, heatsink and connectors, 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 TESLA M3 SAE/ECE LG Reverse LH BU180, TESLA M3 SAE/ECE LG Reverse RH BU180 and P552 FRONT PRK TRN GEN2 BU168, 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