CLA-2-85:OT:RR:NC:N2:209
Patrick Fitzgerald
Lightspeed Aviation
6135 Jean Rd
Lake Oswego, OR 97035
RE: The tariff classification of PCBAs from China
Dear Mr. Fitzgeralds.
In your letter dated March 11, 2025, you requested a tariff classification ruling.
The first item concerned is a printed circuit board assembly (PCBA), product code - 200-00025-000.A6
PCBA, Upper. This PCBA is to be incorporated within the control box of the PFX Aviation headset.
The PFX Aviation headsets are used within an aircraft by the pilot or passenger. The headsets are wired and
must be plugged in, to communicate with ATC (air traffic control) or communicate within the cockpit while
in flight. The headsets also provide noise canceling functions.
There is an upper cable that connects the control box assembly to the headset and a lower cable that connects
the control box assembly to the intercom of the aircraft.
The control box consists of a plastic housing that incorporates various control buttons. The PCBA is located
within the plastic housing of the control box.
The upper PCBA incorporates a CPU chip as well as flash memory. This PCBA provides the main
processing and noise cancelation functionality to the headset. Without this board, the headset would be
unable to perform noise cancellation
The second item concerned is a PCBA, product code - 200-0003-000.A7 PCBA, ANR, Left. This PCBA is to
be incorporated with the left ear cup of a Sierra Aviation headset.
The Sierra Aviation headset is used within the aircraft by the pilot or passenger. The headsets are wired and
must be plugged in, to communicate with ATC (air traffic control) or communicate within the cockpit while
in flight. The headsets also provide noise canceling functions.
Product code 200-00003-000.A7 PCBA, ANR, Left – is an impregnated glass PCB with 3 or more layers of
conductive materials. It is populated with various active and passive electrical elements. It is only used within
noise canceling headsets. It’s incorporated within the left ear cup of the Sierra headset. Its function is to
transmit power from the control box to the speakers and to facilitate the noise cancellation functions. The
intent is to hear air traffic control without background noise interfering with the audio transmission. This
PCB cannot be used for any other function.
The third item concerned is a PCBA, product code - 200-00024-000.A4 PCBA, Control Box, Lower, Sierra.
This PCBA is to be incorporated within the control box of the Sierra Aviation headset
Product code 200-00024-000.A4 PCBA, Control Box, Lower, Sierra - is an impregnated glass PCB with 3 or
more layers of conductive materials. It is populated with various active and passive electrical elements. It is
only used within the control box of noise canceling headsets. It transmits power from an AA battery to the
headset. There are physical buttons, and a Bluetooth chip mounted to this PCBA as well. The intent is to hear
air traffic control without background noise interfering with the audio transmission. This PCB cannot be used
for any other function.
There is an upper cable that connects a control box assembly to the headset and a lower cable that connects
the control box assembly to the intercom of the aircraft.
This PCBA is mounted within the housing of the control box assembly. The PCB acts as a sound processor.
This PCB transmits information selected on the control box to the helmet cups, such as volume controls
The applicable subheading for each of the above mentioned PCBAs (product code - 200-00025-000.A6
PCBA, Upper, product code - 200-0003-000.A7 PCBA, ANR, Left and product code - 200-00024-000.A4
PCBA, Control Box, Lower, Sierra), will be 8518.90.8100, Harmonized Tariff Schedule of the United States
(HTSUS), which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in
their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting
of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier
sets; parts thereof: Parts: Other: Other.” The general rate of duty will be Free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8518.90.8100, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8518.90.8100, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03,
in addition to subheading 8518.90.8100, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division