CLA-2-94:OT:RR:NC:N4:110
Ms. Nithya Nagarajan, Esq.
Law Office of Nithya Nagarajan, LLC
9101 Friars Road
Bethesda, MD 20817
RE: The tariff classification of parts for lighting fixtures from China, Korea and Taiwan
Dear Ms. Nagarajan:
In your letter dated September 4, 2015, on behalf of your client Intense Lighting, LLC, you requested a tariff classification ruling.
The articles under consideration comprised of three component parts for LED lighting fixtures identified as aluminum die-cast housing, aluminum reflectors and galvanized steel housing. These component parts will be used in various lighting fixtures including commercial hospitality, supermarket, retail and residential markets. The products offered by the importer ranges from LED downlights, tracklights, and recessed multiples, etc.
Item 1 is an Aluminum Diecast Housings, part number 230050 Vertical Housing comprised of several component parts. The component materials are of diecast aluminum of grade A380. The principle use of the aluminum housing is to house the lamp/LED and the ballast/driver part of a completed lighting fixture used in LED lighting fixtures. It is stated that the aluminum diecast housing is specifically designed for a lighting fixture, Model MBLXXXXX and cannot be used as a part of another LED lighting fixture.
Item 2 is an Aluminum Reflector comprised of a dome shaped circular reflector that functions as the casing of a lighting fixture to reflect the light emitted by the light source and disperse it via the completed lighting fixture. The reflector is installed behind the LED to reflect the necessary light after the LED lighting fixture is completely assembled. The aluminum reflector is made of a stamped aluminum of grade 1100-O. The principle use of the aluminum reflector is to focus the light that is emitted from the lamp/LED as part of a completed lighting fixture used in a rack luminaire or recessed luminaire. The reflector is specifically designed for Model MBLXXXXX lighting fixture.
Item 3 is a Galvanized Steel Housing, part number 470348 LED New Construction Housing 4". This item is comprised of several component parts including a junction box, a flat plate, a circular shaped flat plate, a dome shaped circular reflector, which functions as the casing of a lighting fixture within which the light source is then mounted to complete the finished lighting fixture. The galvanized steel housing is manufactured with galvanized steel of A653. The principal use of the galvanized steel housing is for junction boxes and plaster frames as part of a completed lighting fixture used in recessed luminaires used in dry or damp locations. They are specifically designed for Model SS4G2200 lighting fixtures.
The applicable subheading for the Aluminum Diecast Housings, part number 230050 Vertical Housing, the Aluminum Reflector, and the Galvanized Steel Housing, part number 470348, will be 9405.99.4090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Lamps and lighting fittings…and parts thereof not elsewhere specified or included: Parts: Other: Other." The general rate of duty will be 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