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 November 16, 2025, you requested a tariff classification ruling.
There are four parts which are the subject of this ruling:
303-00012-000.B1 Spring Enclosure, Outer
303-00015-000.B1 Faceplate, Left
303-00016-000.B1 Driver Cover
303-00024-000.B1 Cover, Acoustic Vent.
Each of the above cited parts are components of Lightspeed’s Sierra Aviation Headset.
The Spring Enclosure (303-00012-000.B1) would be affixed to and located on the inside of the
headband assembly.
Its functional roles include:
Structural Protection - Shields internal components from physical damage, dust, and moisture.
Cable Management - Houses or routes the wires connecting the ear cups keeping them secure and
reducing strain.
Noise Isolation Support - Helps maintain the integrity of the noise-canceling system by sealing gaps
that could let ambient sound in.
Ergonomic & Comfort Contributions - Smooth Surface Contact. Provides a clean, smooth interface
between the headband and the pilot’s head, reducing irritation or pressure points.
Weight Distribution - Can contribute to balancing the headset’s weight, improving long- term comfort
during extended flights.
Manufactured from MN6-FG20 BK, which is a type of plastic, specifically a glass-fiber-reinforced
Polyamide 66 (Nylon 6/6). Materials used meets FAA or EASA regulations for flammability, and
EMI shielding.
The Face Plate (303-00015-000.B1) would be affixed to the left ear cup assembly.
Its functional roles include:
Structural Support for Driver/Speaker - Holds the driver unit (the part that produces sound) securely
in place. It ensures precise alignment within the ear cup, which is essential for consistent sound
quality and effective ANC (Active Noise Canceling).
Acoustic Optimization - The design and material of the face plate can influence sound resonance,
vibration damping, and frequency response.
Integration with Noise-Canceling Microphones - Helps support microphone to optimally detect
ambient noise.
Isolation and Sealing - Contributes to acoustic sealing, which is vital for passive noise isolation.
Manufactured from Bayblend FR-110, which is a flame retardant PC/ABS copolymer plastic with
super- high melt flow and high impact strength even at low temperatures.
The Driver Cover (303-00016-000.B1) would be affixed to the left ear cup assembly.
Its functional roles include:
Protects the Speaker Driver - Shields the delicate driver diaphragm from dust, debris and physical
damage. Prevents wear and tear that could degrade sound quality over time.
Acoustic Tuning - Can reduce unwanted resonances and smooth our frequency response, especially in
the mid and high ranges.
Structural Integration - Helps maintain internal geometry of the earcup, which is vital for consistent
ANC (Active Noise Cancelation) performance. Ensures that the driver remains properly aligned with
the ear cup and the microphones.
Manufactured from MN6-FG20 BK which is a type of plastic, specifically a glass-fiber- reinforced
Polyamide 66 (Nylon 6/6).
Acoustic Vent Cover (303-00024-000.B1) - would be affixed to the ear cups. This piece securely holds
an acoustic vent that controls airflow and sound wave movement, which helps manage pressure and
resonance inside of the cup assembly.
Its functional roles include:
Precise Vent Placement - Ensures the vent is located exactly where it needs to be to manage airflow
and sound wave behavior. This precision helps tune the headsets acoustic response, especially for
low-frequency noise attenuation.
Structural Integrity - Prevents the vent from shifting or vibrating, which could introduce unwanted
noise or reduce the effectiveness of passive noise isolation.
Acoustic Tuning - The shape and material of the Vent Cover influences how sound wavs interact with
the vent. The plastic composition is lightweight and non-resonant properties helps to dampen
vibrations and avoid sound coloration.
Integration with ANC System - Can be designed to work in harmony with microphones and speakers,
ensuring that the ANC system receives clean, predictable acoustic input.
Environmental Protection - Helps assist shielding the vent from dust, moisture, and debris.
Manufactured from Akulon K222-D which is a low-viscosity, food- contact grade of polyamide 6 (PA
6), or nylon 6 plastic.
The applicable subheading for the each of the items concerned (303-00012-000.B1 Spring Enclosure, Outer),
(303-00015-000.B1 Faceplate, Left), (303-00016-000.B1 Driver Cover), (303-00024-000.B1 Cover, Acoustic
Vent) 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