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 China
Dear Ms. Ratto:
In your letter dated October 31, 2025, you requested a tariff classification ruling.
There are two items concerned, both of which are components of aviation headsets.
The first item is referred to as the “Sub-Assy, Module, PCB, GA,” item # 260-00076-000.A1. This module is
a critical component of the Delta Zulu noise-canceling aviation headset. This module incorporates two
electric/audio cables: one will be connected/assembled into the ear cup of the aviation headset, the other has
two audio plugs that would be used to plug the headset into the audio panel of the aircraft. The module
houses three printed circuit board assemblies (PCBAs) that powers the active noise cancellation function,
processes incoming sound via the microphones, and generates anti-noise signals, etc. The module also allows
pilots to adjust volume levels, select stereo/mono functions, supply power (module contains the battery
compartment), and manage power distribution to the headset's microphones, speakers and Active Noise
Cancellation (ANC) circuitry. The module acts as the interface between the headset and the aircraft’s audio
panel and provides Bluetooth functionality for wireless audio functions.
There are three PCBAs within the module made of three or more layers of conductive materials and
populated with various active/passive electrical elements. The upper and lower module housings are made of
ABS-PC, which is a thermoplastic blend of polycarbonate (PC) and acrylonitrile-butadiene-styrene (ABS).
The attached cables are made of tinsel wire, and incorporate a 5POS connector, a Comm 6.3 stereo plug and
a MIL 5.2 stereo plug.
The second item is referred to as “Control Box, Battery with Cables - Sierra,” item # 285-00027-200.A4.
This module is a critical component of the Sierra noise-canceling aviation headset. It incorporates two
electric/audio cables, one will be connected/assembled into the ear cup of the aviation headset, the other
cable has two audio plugs that would be used to plug the headset into the audio panel of the aircraft. This
module houses two printed circuit board assemblies that are used to power the active noise cancellation
function, process incoming sound via the microphones, generate anti-noise signals, etc. The module also
allows pilots to adjust volume levels, select stereo/mono functions, supply power (module contains the
battery compartment), and manage power distribution to the headset's microphones, speakers and ANC
circuitry. This module acts as the interface between the headset and the aircraft’s audio panel.
There are two PCBAs within this module made of three or more layers of conductive materials and populated
with active/passive electrical elements. The upper and lower module housings are made of ABS-PC. The
attached cables are made of tinsel wire, and incorporate a 5POS connector, a Comm 6.3 stereo plug and a
MIL 5.2 stereo plug.
The applicable subheading for both modules the “Sub-Assy, Module, PCB, GA,” item # 260-00076-000.A1,
and “Control Box, Battery with Cables - Sierra,” item # 285-00027-200.A4, 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 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 10 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 8518.90.8100, 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. 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 8518.90.8100, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8518.90.8100, 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 8518.90.8100, 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 Steven Pollichino at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division