CLA-2-85:OT:RR:NC:N2:209
Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of aviation headband parts from China
Dear Ms. Ratto:
In your letter dated October 3, 2025, you requested a tariff classification ruling.
The items concerned are all parts of the Zulu 3 aviation headset. The parts in question are referred to as a
Slider and Headband Clamps. The 3 applicable SKU numbers are 303-00057-100.A5 (Slider Clamp Top),
303-00058-100.A4 (Slider Clamp Bottom), and 303-00194-000.A1 (Headband Clamp Bottom).
All three items are parts that will be affixed to the headband assembly of the Zulu 3 aviation headset. These
parts are made of PA Type 6 15GF, which is a type of glass fiber reinforced polyamide 6 (Nylon 6) material
that contains 15% glass fiber. This reinforcement makes the material stronger, more rigid, and more resistant
to heat and chemicals than standard Nylon 6, a type of thermoplastic. The parts in question are molded to a
specific shape and incorporate screw holes and other design elements that make them solely for use as a part
of the aviation headset.
The applicable subheading for the each of the aviation headset parts, SKU numbers 303-00057-100.A5
(Slider Clamp Top), 303-00058-100.A4 (Slider Clamp Bottom), and 303-00194-000.A1 (Headband Clamp
Bottom), will be 8518.90.8100, Harmonized Tariff Schedule of the United States (HTSUS), which provides
for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones
and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or
more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Parts:
Other: Other”. The general rate of duty will be Free.
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 8518.90.8100, 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 8518.90.8100, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8518.90.8100, 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 8518.90.8100, 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.
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 Steven Pollichino at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division