CLA-2-85:OT:RR:NC:N2:209
Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of a printed circuit board assembly from China
Dear Ms. Ratto:
In your letter dated October 21, 2025, you requested a tariff classification ruling.
The item concerned is referred to as the 200-00033-000.A6 Printed Circuit Board Assembly, Transceiver,
Tango. This item is the main printed circuit board assembly (PCBA) used within the wireless control
box/panel interface for the Lightspeed’s Tango Aviation Headset. The control box/panel interface is a
separate module that would be situated between the Tango aviation headsets and the aircrafts
communications panel. It allows for the wireless transmission/reception of data between the headset and the
panel.
The control box/panel interface is the vital hub of the Lightspeed Link system. It routes communication
between the headset, the intercom, and auxiliary devices. The PCBA in question, incorporates the electrical
elements that facilitates all of the transmission and reception functions (i.e.. the PCBA transmits audio from
transceiver to Headset (Bluetooth), Receives Audio from headset (Boom Mic) (short range FM radio),
Transmits/Receives audio from additional Bluetooth devices (such as smartphone)).
The applicable subheading for the 200-00033-000.A6 Printed Circuit Board Assembly, Transceiver, Tango,
will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for
“Telephone sets, including smartphones and other telephones for cellular networks or for other wireless
networks; other apparatus for the transmission or reception of voice, images or other data, including
apparatus for communication in a wired or wireless network (such as a local or wide area network)…: Other
apparatus for transmission or reception of voice, images or other data, including apparatus for
communication in a wired or wireless network (such as a local or wide area network): Machines for the
reception, conversion and transmission or regeneration of voice, images or other data, including switching
and routing apparatus: 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 8517.62.0090, 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. Your product falls
within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to
your product classification, i.e. 9903.01.32, in addition to subheading 8517.62.0090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 8517.62.0090, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8517.62.0090, 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 Steven Pollichino at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division