CLA-2-94:OT:RR:NC:N4:110
Mr. Peter M. Zubrin
Sandler & Travis Trade Advisory Services, Inc.
36555 Corporate Drive, Suite 400
Farmington Hills, Michigan 48331
RE: The tariff classification of an LED light fixture from Japan
Dear Mr. Zubrin:
In your letter dated November 26, 2014, you requested a tariff classification ruling on behalf of your client Keyence Corporation of America (Keyence.)
The prospective importation is identified as the LED Ring Light, Item Number CA-DRR10F (“CA light”.) Based on the sample and the information provided, the CA light is a light fixture comprised of a “ring” shaped lamp populated with 216 LEDs encased in a plastic housing. The light fixture measures approximately 1.75 inches tall by 4 inches in diameter with a 2 inch cutout in the center. An electrical wire with a plug is attached to the side of the housing for providing power supply. The back of the housing features four screw holes for mounting. It includes mounting hardware, which consists of a metal bracket with four screws. It is stated that the item is for use in the Keyence CV and XG Vision System(s). It is used to illuminate an object that is passing in front of a CV digital still image video camera. The round shape provides illumination from 360 degrees around the camera, which provides even illumination of the target.
You proposed classification in subheading 8543.70.70, Harmonized Tariff Schedule of the United States (HTSUS), as “Electrical machines and apparatus…: Other machines and apparatus: Electric luminescent lamps”. As imported, Item Number CA-DRR10F consists of an array of LEDs in a housing, and an attached electrical wire equipped with a plug. As such, this item is beyond the scope of LED lamps classified in 8543.70.70, HTSUS, therefore, subheading 8543.70.7000, HTSUS, would not be appropriate.
The applicable subheading for the LED Ring Light, Item Number CA-DRR10F, will be 9405.40.8000, HTSUS, which provides for "Lamps and lighting fittings…: Other electric lamps and lighting fittings: Other." The general rate of duty will be 3.9 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