Mr. Michael Guan
Unipac Shipping Inc.
182-16 147th Avenue
2nd Floor
Jamaica, NY 11413

RE: The tariff classification of outdoor public lighting from China.

Dear Mr. Guan:

In your letter dated January 9, 2010, you requested a tariff classification ruling on behalf of your client, Rab Lighting.

The merchandise under consideration is the LPack LED Luminaire. A sample was submitted with your ruling request and will be returned to you.

The LPack consists of a wedge-shaped metal housing measuring approximately 10¾ inches long by 4¾ inches wide by 2¼ inches high at its widest points. The housing encases a reflector and 9 LED (light emitting diode) lights arranged in a 3 by 3 grid under a glass lens, and is designed to be hard-wired in a permanent, fixed position for lighting public areas. The LPack is rated for use in wet locations, and may be either wall- or pole-mounted. Applications include pathway lighting, lighting outdoor signage, parking areas, and commercial and residential buildings.

In your ruling request you suggest classification of the LPack LED Luminaire in 8541.40.2000 as light emitting diodes. However, the LPack is a complete lighting fixture consisting of a light emitting diode system mounted within a weather-proof housing with a reflector and lens. As such, it is beyond the scope of 8541.40.2000, which provides merely for just diodes that are light emitting.

The applicable subheading for the LPack LED Luminaire will be 9405.40.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Lamps and lighting fittings…: Other electric lamps and lighting fittings…: Of base metal: Other.” The general rate of duty will be 6 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

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 Thomas Campanelli at (646) 733-3016.


Robert B. Swierupski
National Commodity Specialist Division