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 ear cup module for an aviation headset from the Philippines
Dear Ms. Ratto:
In your letter dated November 16, 2025, you requested a tariff classification ruling.
The item concerned is referred to as an “Assembly, Ear Cup, Left, H Mod” that is used in the production of
aviation headsets. The applicable SKU number is 285-00060-000.A1. This item is a component of
Lightspeed’s Zulu H Mod Cup Kit. It is essentially the left ear cup of the internally mounted headset used
within the helmet of helicopter pilots.
This item contains a speaker, microphones and a printed circuit board assembly (PCBA). The ear cup
provides audio to the pilot while also enabling Active Noise Reduction (ANR). The microphones detect
ambient cockpit noise, and the PCBA processes the signal to generate an anti-noise waveform through the
speakers, canceling unwanted sound. The ear cup interfaces with the helmet’s control box via an upper cable
and forwards signals to the aircraft intercom through a lower cable. There are foam layers in the cup which
provide passive noise attenuation, forming a tight seal around the ear to block external noise.
The applicable subheading for the “Assembly, Ear Cup, Left, H Mod,” SKU number 285-00060-000.A1 will
be 8518.30.2000, 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: Headphones
and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or
more loudspeakers: 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 8
518.30.2000, 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