CLA-2-85:OT:RR:NC:N2:209
Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of an aviation headset part from the Philippines
Dear Ms. Ratto:
In your letter dated October 31, 2025, you requested a tariff classification ruling.
The item concerned is a headband assembly (Part # 285-00023-000.A2) for Lightspeed’s Sierra aviation
headset. The housing/structure of the headband assembly is made from ABS-PC - a thermoplastic blend of
polycarbonate (PC) and acrylonitrile-butadiene-styrene (AB). The headband incorporates insulated electrical
wiring, connectors and a spring.
The functions of this item include:
Maintaining a secure fit - A sturdy headband keeps the ear cups pressed gently but firmly against your
ears. This helps the ear seals form a tight seal, which is essential for blocking out external noise.
Supporting consistent positioning - Noise canceling works best when the headset is properly aligned. A
rigid headband ensures the ear cups stay in the right place, so the microphones and speakers used in
active noise canceling can do their job effectively.
Durability and Longevity - Hard plastic is lightweight but strong, so it can handle daily wear and tear
without losing its shape. This allows the headset to continue performing effectively over time.
Comfort with Structure - When paired with soft head pads, the hard plastic provides structure without
sacrificing comfort.
The applicable subheading for the headband assembly (Part # 285-00023-000.A2) 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