CLA-2-90:OT:RR:NC:N1:105
Axel Schönbeck
Noisy Labs GmbH
Luruper Hauptstraße 1
Hamburg 22547
Germany
RE: The tariff classification of Balanced Detectors from Germany
Dear Mr. Schönbeck:
In your letter dated July 10, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The items under consideration are described as Balanced Detectors (model numbers BD-HQE-1550 and
BD-HQE-1064), which are high-quantum efficiency (HQE) balanced photodetectors designed for operation
at a wavelength of 1550 nanometers (nm) and 1064 nm respectively. Balanced Detectors are devices that
utilize two precisely matched photodiodes and a differential amplifier to subtract two optical input signals
from each other. This subtraction process effectively cancels out common-mode noise (like laser intensity
fluctuations) present in both inputs, significantly improving the signal-to-noise ratio. HQE indicates the
detector is highly efficient at converting incoming photons into electrical signals. This is crucial for detecting
weak optical signals, such as those encountered in quantum optics or astronomy. The 1550 nm and 1064 nm
wavelength specify the optimal wavelength range for which the detector is designed to operate. The 1550 nm
wavelength is important in optical communication applications, particularly for fiber optic systems, as it falls
within a low-loss transmission window for optical fibers. The BD-HQE-1064 is a specialized photodetector
designed for sensitive measurements, especially in fields like quantum optics and optical coherence
tomography (OCT).
The Balanced Detector consists of a laser beam detector housed in a casing (dimensions: 81.7 mm x 136 mm
x 29 mm), a connector for an external electronic demodulation signal, and a base adjusted for a laser beam
height of 50 mm for mounting on an optical bench. The balanced homodyne detector comprises two
photodiodes for detecting optical signals. Each diode is separately illuminated with a laser beam and converts
the incident optical signal into a photocurrent. The difference between these photocurrents is converted into a
voltage, which can be directly read from a DC output. The AC output of the device provides the signal after it
passes a transimpedance amplifier and is filtered by a high-pass filter with a cut-off frequency of 300 kHz or
a different customized value. Additionally, the voltage signal can be mixed with a demodulation signal. The
result of this mixture can be taken from the demodulation output. All inputs and outputs are equipped with
SMA (SubMiniature version A) connectors. Laser radiation is directed and measured onto the two integrated
photodiodes via mirrors and lenses.
In your letter, you suggest the applicable subheading for the Balanced Detectors to be 9027.89.8090,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Instruments and apparatus
for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke
analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion,
surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or
light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and
apparatus: Other: Other: Other: Other.” We disagree. A Balanced Detector’s primary function is to detect and
measure light signals. Specifically, it subtracts two optical input signals from each other, which helps to
minimize common-mode noise and isolate the desired signal. Optical devices are instruments that work with
light, either by detecting it, manipulating it, or using it to gather information. Additionally, the Balanced
Detectors are considered electrical per Chapter 90 Additional U.S. Note 2. Therefore, the appropriate
subheading is accounted for earlier in heading 9027, HTSUS.
The applicable subheading for the Balanced Detectors (model numbers BD-HQE-1550 and BD-HQE-1064)
will be 9027.50.4060, HTSUS, which provides for “Instruments and apparatus for physical or chemical
analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus);
instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the
like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including
exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus using optical
radiations (ultraviolet, visible, infrared): Other: Electrical: Other.” The general rate of duty will be free.
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
9027.50.4060, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division