CLA-2-85:OT:RR:NC:N2:209
Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of foam components for aviation headsets from the Philippines
Dear Ms. Ratto:
In your letter dated October 29, 2025, you requested a tariff classification ruling.
The items concerned are foam cups used in Lightspeed’s aviation headsets. The applicable SKU numbers are
250-00013-000.B1 and 315-00080-000.A1.
The first item is the foam cup (250-00013-000.B1 Foam, Cup) used within the Sierra aviation headset. The
foam cups are shaped pieces of polyester filter foam that have 80 pores per inch. This foam piece gets
installed within the ear cups of the headset.
The second item is the foam cup (315-00080-000.A1 Foam, Cup) that is part of the audio components (LSA
56 Cup Kit) used within the HGU-56 aviation Helmet. Side 1 of this foam cup is made of a polyester filter
foam with 80 pores per inch. Side 2 of this Foam Cup is made of double-sided adhesive with polyester paper.
This foam piece gets installed over the ear cup assembly of the audio components (LSA 56 Cup Kit) of the H
GU-56 aviation Helmet.
Both models of foam cups are used for:
Sound Absorption - Foam is made of tiny pockets of air and soft material. When sound waves hit it, the
foam absorbs some of the energy instead of letting it bounce around. This reduces the amount of noise
that reaches your ears.
Blocking Sound - Foam also acts as a physical barrier. It blocks outside noise from entering your ears,
especially high frequency sounds like chatter or keyboard clicks.
Comfort and Seal - Foam ear cushions create a snug fit around your ears. This seal helps prevent sound
from leaking in or out, which improves both passive and active noise canceling.
The applicable subheading for both models of the foam cup (250-00013-000.B1 and 315-00080-000.A1) 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 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 Philippines
will be subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report
the Chapter 99 heading applicable to your product classification, i.e. 9903.02.53, in addition to subheading
8518.90.8100, 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