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 part for an aviation headset from China
Dear Ms. Ratto:
In your letter dated November 22, 2025, you requested a tariff classification ruling.
The item concerned is referred to as the H Mod Fabric Cover Insert, 250-00045-000.A4. The H Mod Fabric
Cover Insert is solely used with Lightspeed’s Zulu aviation helmet and is a component of the H Mod Cup
Kit. This article would be adhered onto the speaker plate assembly of the the ear cup.
Functions:
Prevents dust, dirt, and small debris from entering the speaker driver, which could degrade audio
quality or damage components.
Maintains consistent airflow and acoustic properties, ensuring the noise-canceling system works as
intended.
Protects the sensitive electronics and speaker diaphragm from sweat or humidity, reducing the risk of
corrosion or electrical failure.
Provides a soft layer between the ear and the hard speaker grille, improving comfort during extended
use.
The cover is designed to be acoustically transparent, so it doesn’t block sound or interfere with active
noise cancellation.
Maintains a uniform seal and prevents sound leakage caused by uneven contact.
This article is made from a PVC structure (outer shaped frame), a fabric layer of Lycra, and an adhesive ring
(3M 468 200MP adhesive tape).
The applicable subheading for the H Mod Fabric Cover Insert, 250-00045-000.A4 will be 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.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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)
Evan Conceicao
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division