CLA-2-85:OT:RR:NC:N2:212
Cordell Maines
Lumibird Photonics USA, Inc.
49 Willow Peak Drive
Bozeman, MT 59718
RE: The tariff classification of a smart power supply from France
Dear Mr. Maines:
In your letter dated October 24, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the ICE-Q Smart Power Supply. The subject device is
comprised of a main power board, which encompasses the conversion electronics as well as the electrical
control and other power components. This board is encased within a plastic housing that also contains liquid
and air-cooling technology. The exterior of the complete unit has a touch screen LCD for control and
monitoring. You state that the subject power supply is rated at 760W and is designed to be used exclusively
to power and cool the Q-Smart laser system.
In your request, you suggest that the correct classification for the power supply is under subheading
8504.40.95, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the ICE-Q Smart Power Supply will be 8504.40.9540, HTSUS, which
provides for “Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof:
Static converters other: Rectifiers and rectifying apparatus: Power supplies: 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 of the European
Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15
percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General
duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.02.20, in addition to subheading 8504.40.9540, 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 Luke LePage at [email protected].
Sincerely,
(for)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division