CLA-2-85:OT:RR:NC:N2:212
Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of cables for aviation headsets from China
Dear Ms. Ratto:
In your letter dated October 24, 2025, you requested a tariff classification ruling.
There are three different cables with this request that are designed for the Delta Zulu aviation headset. This
headset is used within an aircraft by the pilot or passenger. The headset is wired and must be plugged into an
audio jack of the intercom to communicate with air traffic control (ATC) or within the cockpit while in flight.
The headset also provides noise cancellation for effective communication between pilot and passenger. Each
cable is designed to provide compatibility with different types of aircraft instrument panels. We note that the
aviation headset is not imported with the cables and is not addressed in this ruling.
The first item is identified as the Dual GA cable, part number: 300-00050-002.A2. This cable features a
Y-split cable with a 1.25mm pitch connector on the single-cable side for connection to the headset’s control
box and the two resulting ends of the split cable are terminated with 6.3mm and 5.2mm connectors. The
connectors are knowns as Dual GA plugs and the 6.3.mm connector is used for incoming audio to the earcup
speakers and the 5.2mm connector is dedicated to transmitting signals from the microphone.
The second is identified as the U-174 cable, part number: 300-00051-000.A6. This cable consists of a single
cable with a 1.25mm pitch connector on one end for the permanent connection to the headset’s control box
and the other end is terminated with an audio connector known as Heli (U-174) plug. This type of cable is
used specifically for helicopters.
The third is identified as the Panel cable, part number: 300-00052-000.A7. The cable is comprised of two
1.25mm pitch connectors on one end for the permanent connection to the headset’s control box and the other
end is terminated with a 6-pin Lemo connector. The connector allows the headset to receive audio signals and
electrical power directly from the aircraft panel, eliminating the need for batteries or external power modules.
The applicable subheading for the Dual GA cable, part number: 300-00050-002.A2, U-174 cable, part
number: 300-00051-000.A6, Panel cable, part number: 300-00052-000.A7 will be 8544.42.9090,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Insulated (including
enameled or anodized) wire, cable (including coaxial cable) and other insulated electric conductors, whether
or not fitted with connectors; optical fiber cables, made up of individually sheathed fibers, whether or not
assembled with electric conductors or fitted with connectors: Other electric conductors, for a voltage not
exceeding 1,000 V: Fitted with connectors: Other: Other: Other.” The general rate of duty will be 2.5
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 8544.42.9090, HTSUS, listed above.
On July 30, 2025, Presidential proclamation 10962 imposed additional tariffs on certain semi-finished copper
and intensive copper derivative products. Additional duties for semi-finished copper and intensive copper
derivative products of 50 percent upon the value of the copper content are reflected in Chapter 99, heading
9903.78.01. The non-copper content of these products, provided for in heading 9903.78.02, is not subject to
the additional ad valorem duties. At the time of entry, for the copper content you must report heading
9903.78.01, in addition to subheading 8544.42.9090, HTSUS. For the non-copper content, you must report
heading 9903.78.02, in addition to subheading 8544.42.9090.
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. For products
covered by heading 9903.78.01, this additional duty applies to the non-copper content of the merchandise.
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 8544.42.9090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8544.42.9090, 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 8544.42.9090, 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 Luke LePage at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division