CLA-2-85:OT:RR:NC:N4 410
Paola Sacaj
Faunalux Ltd.
71-75 Shelton Street
London WC2H 9JQ
United Kingdom
RE: The tariff classification of LED lamps from China
Dear Ms. Sacaj:
In your letter dated June 2, 2025, you requested a tariff classification ruling. Product images and descriptive
literature are submitted in your ruling request.
The merchandise under consideration is identified as the E26 screw and E27 screw. The E26 screw and E27
screw are light-emitting diode (LED) lamps that consist of a heat sink containing the LEDs and other
electrical and electronic components with a lens. They are in PAR shape, and each have an E26 or E27 screw
cap to be screwed onto a lighting fixture. It is stated that the LED lamps are all of a near-identical
form-factor, and are for identical use. The lamps utilize the LED technology providing light for exotic
animals (such as reptiles, turtles, etc.) that are sometimes kept as pets or in zoos as display or educational
animals.
It is also stated that the E26 screw features the unique factor in use for the product’s Ultraviolet A radiation,
which is an essential part of animal welfare for these exotic animals. The Ultraviolet output has been tested to
harmonized standard IEC 62471, and the products are marked as “Risk Group 2”, which means that they are
not a risk to humans due to natural photo-aversion. On the other hand, the E27 screw features an acid-etched
quartz lens, designed only for use with animals commonly kept as pets in dry conditions in terraria or vivaria.
The applicable subheading for the E26 screw and E27 screw LED lamps will be 8539.52.0030, Harmonized
Tariff Schedule of the United States (HTSUS), which provides for “Electrical filament or discharge lamps,
including sealed beam lamp units and ultraviolet or infrared lamps; arc lamps; light-emitting diode (LED)
light sources; parts thereof: Light-emitting diode (LED) light sources: Light-emitting diode (LED) lamps; Of
a type specified in statistical note 7(c) to this chapter”. The rate of duty will be 2 percent 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 8539.52.0030, HTSUS, listed above.
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. At this time products from all 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, i.e. 9903.01.25, in addition to subheading
8539.52.0030, 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.
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 Michael Chen at [email protected].
Sincerely,
(for)
Steven A. Mack
Director
National Commodity Specialist Division