CLA-2-90:OT:RR:NC:N2:212
Richard Redpath
Parhelion Incorporated
109 Blythewood Ct
Cary, NC 27513
RE: The tariff classification of a tactical laser light from China
Dear Mr. Redpath:
In your letter dated March 15, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the Stripelight Fire, Rescue, and Tactical (FRT) light.
The subject light is described as a handheld laser light source with optional LED light used primarily by first
responders in environments where smoke and fire are present. The unit consists of a motherboard and
processor enclosed within a housing. At the top of the housing is the laser and LED light source. The device
is powered by a rechargeable battery.
When the user finds themselves in a smoke-filled environment, they initiate the device, which projects a laser
grid. This grid creates a reference plane, which illuminates the smoke and allows the user to track smoke
flow, density, and source. Additionally, the lasers will bounce off walls and other obstacles, including other
individuals, in the immediate area, allowing the user to better navigate their environment. In addition to the
lasers, the optional LED light can be used as an additional light source.
In your request, you suggest that the correct classification for the Stripelight FRT light is subheading
8515.80.0080, Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
The referenced subheading provides for “Electric (including electrically heated gas), laser or other light or
photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding
machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying
of metals or cements; parts thereof: Other machines and apparatus: Other.” Based on the information
provided, the Stripelight FRT is not a machine or apparatus designed for soldering, brazing, welding, or hot
spraying of metal. Thus, classification in heading 8515, HTSUS, would be precluded as the item does not
meet the terms of that heading.
The applicable subheading for the Stripelight FRT will be 9013.80.9100, HTSUS, which provides for
“Liquid crystal devices not constituting articles provided for more specifically in other headings; lasers, other
than laser diodes; other optical appliances and instruments, not specified or included elsewhere in this
chapter; parts and accessories thereof: Other devices, appliances and instruments: Other.” The general rate of
duty will be 4.5% ad valorem.
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 9013.80.9100, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9013.80.9100, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e. 9903.88.15,
in addition to subheading 9013.80.9100, 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 Section 301 trade remedy, 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
https://www.cbp.gov/trade/remedies/301-certain-products-china
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 Luke LePage at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division