CLA-2-85:OT:RR:NC:N2: 209
Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035
RE: The tariff classification of a speaker assembly 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 a Right Speaker Plate. This assembly is used in the production of
Lightspeed’s Zulu 3 aviation headsets. (The applicable SKU number is 285-00018-000.A5).
The Right Speaker Plate houses the speaker, microphone and a printed circuit board assembly (PCBA). It
ensures that pilots can hear all audio cues, including radio transmissions, alerts, and intercom
communications clearly and evenly.
The Right Speaker Plate is constructed from a housing made of molded ABS (Acrylonitrile Butadiene
Styrene), a speaker frame of plastic (PA66+30% glass), a diaphragm, magnet, PCBA , microphone and foam.
The applicable subheading for the Right Speaker Plate (SKU number 285-00018-000.A5) will be
8518.21.0000, 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: Loudspeakers,
whether or not mounted in their enclosures: Single loudspeakers, mounted in their enclosures”. 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
8518.21.0000, 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