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 headset parts from the Philippines
Dear Ms. Ratto:
In your letter dated October 29, 2025, you requested a tariff classification ruling.
The items concerned are referred to as Left and Right Badges that are used in the manufacture of
Lightspeed’s Sierra Aviation Headsets. The two applicable SKU numbers are 250-00019-000.B3 - Left and
250-00020-000.B3 - Right.
These items are used in the production of noise canceling aviation headsets. The Left Badge is utilized on the
left ear cup assembly and the Right Badge is utilized on the right ear cup assembly of the Sierra headset.
Both badges are made from aluminum and serve the functions of:
Structural Support - The badge is made of aluminum and helps reinforce the ear cup’s structure, which
is important for maintaining a tight seal around the ear—critical for both passive and active noise
canceling.
Vibration Control – The badge helps reduce unwanted vibrations or resonance in the ear cup. This can
improve sound clarity and reduce distortion, especially in high-end headsets.
Shielding - Aluminum creates a shielding effect against electromagnetic interference, which helps
protect the sensitive electronics used in active noise canceling systems.
Aesthetic and Branding - While not directly related to noise canceling, aluminum badges give the
headset a premium look and feel, which can be important for professional or consumer-grade models.
The applicable subheading for the Left and Right Badges, SKU numbers 250-00019-000.B3 - Left and
250-00020-000.B3 - Right, 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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division