CLA-2-85:OT:RR:NC:N2:209
Patrick Fitzgerald
Lightspeed Aviation
6135 Jean Rd
Lake Oswego, OR 97035
RE: The tariff classification of parts of aviation headsets and helmets from China
Dear Mr. Fitzgerald:
In your letter dated March 11, 2025, you requested a tariff classification ruling.
The first items concerned are two printed circuit board assemblies (PCBAs), product code 200-00025-001.A6
PCBA, Upper, and product code 200-00026-000.B1 PCBA, Lower. These PCBAs are to be incorporated
within the control module 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.
The control module consists of a plastic housing that incorporates various control buttons. The control
module will be assembled with the aviation headsets, connected to the electric/audio cable, between the
headset and the input/output connectors. The PCBAs are located within the plastic housing.
The upper PCBA incorporates a CPU chip as well as flash memory. This PCBA provides the main
processing and noise cancellation functionality to the headset. Without this board, the headset would be
unable to perform noise cancellation
The lower PCBA acts as a sound processor for the headsets. This PCBA transmits information selected on
the control box to the headset, such as volume controls.
The second items concerned are PCBA’s, product code 200-00040-000.A2 PCBA, Left, Helmet and product
code 200-00041-000.A2 PCBA, Right, Helmet. These PCBAs are to be incorporated within the ear cup
assembly of the HGU-56 Helmet. The HGU-56 Helmet is a helicopter pilot helmet that has communication
functions and noise canceling attributes.
Both PCBAs are constructed of impregnated glass with 3 or more layers of conductive materials. They are
populated with a variety of active and passive components. They can only be used within noise canceling
headsets/helmets. These PCBAs are installed in the left and right cup assembly of the LSA 56 cup kit, which
then gets assembled within the HGU-56 Helmet. These PCBAs allow for the transmission of power and
audio signals as well as performing a noise canceling function. They allow the user to hear air traffic control
(ATC) without background noise interfering with the audio transmission. These PCBAs cannot be used for
another function.
The applicable subheading for the each of the above mentioned PCBAs, product code 200-00025-001.A6
PCBA, Upper; product code 200-00026-000.B1 PCBA, Lower, product code 200-00040-000.A2 PCBA,
Left, Helmet; and product code 200-00041-000.A2 PCBA, Right, Helmet 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