Ms. Shelly Hess
IJS Global Inc.
12480 NE Marx St.
Portland, OR 97230

RE: The tariff classification of a Round Lamp and Ballast Replacement Kit from China.

Dear Ms. Hess:

In your letter dated June 14, 2011, you requested a tariff classification ruling on behalf of your client International Sourcing Group.

The merchandise under consideration is identified as the Round Lamp and Ballast Replacement Kit (Kit). Based on the information you provided, the Kit consists of a ballast and a round induction lamp, which is a fluorescent lamp without electrodes. The induction lamp is an “O” shaped fluorescent glass tube suspended on two sides by a plastic hanger with an electronic ballast and Edison base screw-in connector for use with a standard Edison base light bulb socket. The Kit is also available with medium and mogul screw-in base connectors. The Kit is designed as a retrofit and will be marketed as a more energy-efficient replacement to existing metal halide or high pressure sodium lamps. It is intended for exterior locations.

In your letter you suggest classification of the Round Lamp and Ballast Replacement Kit under subheading 9405.40.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other electric lamps and lighting fittings. However, this article meets the terms of heading 8539, HTSUS, as an electrical discharge lamp. Inasmuch as it meets the terms of subheading 8539.31.0060, classification within heading 9405, HTSUS, as an other lamp or lighting fitting, would not be appropriate.

The applicable subheading for the Round Lamp and Ballast Replacement Kit will be 8539.31.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical filament or discharge lamps…: Discharge lamps, other than ultraviolet lamps: Fluorescent…: Other: With a single screw-in base.” The general rate of duty will be 2.4 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