Mr. Paul S. Anderson
Attorney at Law
The Anderson Law Firm, LLC
125 S. Wacker Drive
Suite 1825
Chicago, Il 60606

RE: The tariff classification of an LED package with wires from China and Japan

Dear Mr. Anderson:

In your letter dated October 12, 2012, you requested a tariff classification ruling on behalf of your client, Cecol, Inc.

The merchandise subject to this ruling is referred to as an LED Package with wires. The specific model in question is the CL-L241 Series. These LED packages are compact and high efficiency chips, which are further manufactured into modules in need of luminance uniformity and have applications such as in street lights, exterior lights, and down lights.

The “LED Package” portion of the product is identical to merchandise which was the subject of Customs ruling N231155 with the sole exception that lead wires are attached to the CL-L241 Series at the time of importation. The LED Package portion is square-shaped, but may also be more rectangular in nature or assume other shapes reflective of their customization for a specific usage.

Each LED Package contains multiple LED dice or diodes. The base of the LED Package is a substrate, typically made of aluminum or ceramic. Anode and cathode electrodes are located on the substrate on opposite ends of the package. The LED dice are connected to electrodes on the substrate, by means of wire bonding. The dice are then covered with a silicone resin that allows vapor to penetrate inside. The lead wires are simply assembled by connecting them to the LED Package.

In their condition as imported, the LED Package with wires (CL-L241 Series) does not contain any other components such as drivers, housings, switches, bulbs, power service or modules. The subject merchandise is further processed by Cecol’s customer in the United States wherein they are inserted in the modules, attached to a power source, and/or utilize drivers, and/or are inserted into a housing. The purpose of the multiple LED dice or diodes is to achieve more light output once they are further manufactured into modules, which will then contain all of the other components, which are absent from the LED Packages upon importation.

The LED Packages are not LED modules of heading 9405 because they require further manufacturing to produce light, such as a driver, mounting onto a printed circuit board, fittings, and a housing.

The applicable subheading for the LED package with wires (CL-L241 Series) will be 8541.40.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Diodes, transistors, and other semiconductor devices;…: Photosensitive semiconductor devices,…: Light-emitting diodes (LEDs). “ The rate of duty will be free.

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 the National Import Specialist at (646) 733-3015.


Thomas J. Russo
National Commodity Specialist Division