Paul S. Anderson
The Anderson Law Firm, LLC
125 S. Wacker Drive
Suite 1825
Chicago, IL 60606

RE: The tariff classification of COB+ from China and Japan

Dear Mr. Anderson:

In your letter dated August 14, 2014, you requested a tariff classification ruling on behalf of your client, Cecol, Inc.

The merchandise in question is referred to as a COB+, or Chip on Board, which is an assembly of light emitting diodes (LED) on a ceramic substrate. The COB+ is square in shape and measures 24mm X 19mm with a thickness of 1.7mm. Each COB+ product contains multiple LEDs, diodes, rectifiers, resistors, and transistors. Anode and Cathode electrodes are located on the substrate on opposite ends of the board, which is covered with a protective silicone resin coating. There are no lead wires attached to the COB+.

The COB+ is intended to be used as the LED element in a bulb assembly by coupling it with the reflector, heatsink, socket, and various parts to form a complete A19 style LED bulb.

You suggested subheading 8541.40.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Diodes, transistors, and similar semiconductor devices…: Photosensitive semiconductor devices…: Light-emitting diodes.” However, the COB+, a part of an LED bulb, is beyond the scope of heading 8541, and as such classification under subheading HTSUS 8541.40.2000 is inapplicable.

The applicable subheading for the COB+, Part # CLL140-A045A5-30AM1A2, will be 8543.90.8880, HTSUS, which provides for “Electrical machines and apparatus…: Parts: Other: Other: Other: Other.” The rate of duty will be 2.6%.

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 Karl Moosbrugger at


Gwenn Klein Kirschner
National Commodity Specialist Division