CLA-2-85:OT:RR:NC:N2:212
Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of a volume control PCBA from China
Dear Ms. Ratto:
In your letter dated August 20, 2025, you requested a tariff classification ruling.
The merchandise under consideration, model number 200-00035-000.A2, is described as a volume control
printed circuit board assembly (PCBA) used exclusively with the Tango Aviation headset. The subject
PCBA consists of a substrate upon which multiple electrical connectors and a flexible printed circuit
connector are mounted. The PCBA is installed within the headset and used to electrically connect and
control the volume components.
The applicable subheading for the volume control PCBA, model number 200-00035-000.A2, will be
8537.10.9170, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards,
panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for
electric control or the distribution of electricity… For a voltage not exceeding 1,000 V: Other: Other: Other.”
The general rate of duty will be 2.7 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 8537.10.9170, 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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 85437.10.9170, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8537.10.9170, 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 8537.10.9170, 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 United States
Trade Representative and CBP websites, which are available at the following addresses:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions
https://www.cbp.gov/trade/remedies/301-certain-products-china
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 Luke LePage at [email protected].
Sincerely,
(for)
Denise Faingar
Acting Director
National Commodity Specialist Division