CLA-2-85:OT:RR:NC:N2:201
Anthony Santorufo
PakBrite LLC
24800 SW Quarryview Dr
Wilsonville, OR 97070
RE: The tariff classification of bicycle accessories from Taiwan
Dear Mr. Santorufo:
In your letter dated March 31, 2025, you requested a tariff classification ruling.
The items under consideration have been identified as four (4) articles used on bicycles.
The first item has been identified as the “Carbon Capsule Pro”, a rear bicycle safety taillight and storage
compartment accessory for bicycles. You state that this accessory is for outdoor and recreational cycling use.
The integrated LED (Light-Emitting Diode) light enhances rear visibility. The integrated storage
compartment is designed to hold small items such as tire tubes, repair kits, tools, or other cycling accessories.
The entire capsule assembly, including the LED lid, attaches to the bicycle via a proprietary mounting
system (Tri-Fin Mount), which you have also requested a classification determination.
The Carbon Capsule Pro product will include:
• 1x Tri-Fin Mount
• 1x High-Output LED rear Taillight/lid
• 1x Storage container
The Carbon Capsule Pro utilizes a high-output LED as its primary lighting source. The LED light
incorporates multiple lighting modes, including steady and flashing (blinking) patterns, but does not produce
any sound.
The second item has been identified as the “PakLite Mini”, a rear-mounted safety light that attaches to the
bicycle seat post using a quick-release rubberized strap.
The PakLite Mini product will include:
• 1x Seat Post mount and rubber straps, rubber inserts etc.
• 1x High-Output LED rear taillight
The PakLite Mini utilizes a high-output LED as its primary lighting source. The LED light integrated into
the PakLite Mini is designed for use as a rear bicycle taillight and is typically mounted on the bicycle's seat
post. The LED light incorporates multiple lighting modes, including steady and flashing (blinking) patterns,
but does not produce any sound.
In your request you suggest classification of the Carbon Capsule Pro and PakLite Mini in subheading
8512.10.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for, “Electrical
lighting or signaling equipment…: Lighting or visual signaling equipment of a kind used on bicycles:
Lighting equipment”. We disagree.
For CBP purposes bicycle taillights have historically been classified as “visual signaling”, rather than
“lighting” as they provide illumination to identify a rider to motorists for safety reasons, not as a light
necessary for rider navigation.
The applicable classification subheading for the Carbon Capsule Pro and PakLite Mini will be 8512.10.4000,
HTSUS, which provides for “Electrical lighting or signaling equipment…: Lighting or visual signaling
equipment of a kind used on bicycles: Visual signaling equipment.” The rate of duty will be 2.7% ad
valorem.
The third item has been identified as the “PakBrite Fenders”, a modular bicycle accessory designed to
minimize spray and debris from the wheels during outdoor and recreational cycling. You state that they are
intended for use on bicycles to provide protection from water, mud, dirt, and other road or trail contaminants.
The fenders are made from a durable, high-impact-resistant polymer to ensure longevity, flexibility, and
resistance to weather conditions. The fenders were designed to be compatible with your Tri-Fin Mount
system, which secures the fender to the bicycle seat post. The PakBrite Fenders are suitable for rear wheel
applications only.
The fourth, and final item, has been identified as the “Tri-Fin Mount”, a proprietary bicycle accessory
mounting system designed by PakBrite, which serves as a universal attachment point for various PakBrite
products, including the rear safety lights, storage capsules, and fenders. You state that the mount is
engineered for secure and stable attachment to the bicycle's seat post, providing a versatile and modular
solution for integrating multiple cycling accessories. The Tri-Fin mounting device attaches to the bicycle seat
post using 4 bolts/screws.
The applicable subheading for the PakBrite Fenders and Tri-Fin Mount will be 8714.99.8000, HTSUS, which
provides for “Parts and accessories of vehicles of headings 8711 to 8713: Other: Other: Other”. The rate of
duty will be 10% ad valorem.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, 9903.01.25, in addition to the
subheadings, 8512.10.4000 and 8714.99.8000, listed above.
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 Matthew Sullivan at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division