CLA-2-94:OT:RR:NC:N4:110
Ms. Gina M. McClendon
ETI Solid State Lighting Inc.
26650 Renaissance Parkway
Suite 6
Warrensville Heights, OH 44128
RE: The tariff classification of a Recessed Can Retrofit Kit from China
Dear Ms. McClendon:
In your letter dated June 23, 2014, you requested a tariff classification ruling.
The item under consideration is the Recessed Can Retrofit Kit, SKU Number 530175. The item is a 6 inch or 4 inch recessed can light kit with Edison base screw-in LED fixture. The LEDs are contained in the aluminum housing, which measures approximately 7.9 inches in diameter by 3.4 inches tall. The electric wire that is connected to the side of the housing has a screw-in feature at the end. The light fixture is described as the “ETi LED 20 watt, 1200 lumen six inches Recessed Can Retrofit Kit.” The item is designed for commercial and residential use in ceiling can lights.
You have proposed classification under 8543.70.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electrical machines and apparatus…: Other machines and apparatus: Electrical luminescent lamps". The LED Recessed Can Retrofit Kit is beyond the scope of heading 8543, HTSUS, because it is more than a light bulb and it fits the description of lamps and lighting fittings of heading 9405.
The applicable subheading for the Recessed Can Retrofit Kit, SKU Number 530175 will be 9405.10.60, HTSUS, which provides for “Lamps and lighting fittings…: Chandeliers and other electric ceiling or wall lighting fittings…: Of base metal: Other:” The general rate of duty will be 7.6 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 http://www.usitc.gov/tata/hts/.
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 Hope Abada at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division