CLA-2-85:OT:RR:NC:N2 212

Madison Ratto
Lightspeed Aviation
6135 Jean Road
Lake Oswego, OR 97035

RE: The tariff classification of a battery terminal for aviation headsets from China

Dear Ms. Ratto:

In your letter dated November 22, 2025, you requested a tariff classification ruling.

The merchandise under consideration is referred to as a battery terminal (negative), which is identified by part number 260-00003-000.A. The battery terminal is comprised of nickel plated copper with an incorporated spring. The subject terminal will be used in the control box assembly of aviation headsets as an electrical connector. The component serves as the return path for electrical current from the headset’s electronic components back to the battery, enabling the Active Noise Reduction (ANR) system and Bluetooth features to operate. It provides a stable ground reference for the control box’s printed circuit boards, ensuring accurate signal processing for ANR and audio amplification.

The applicable subheading for the battery terminal (negative), part number 260-00003-000.A will be 8536.90.8585, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical apparatus…for making connections to or in electrical circuits…for a voltage not exceeding 1,000 V: Other apparatus: Other: Other.” The general rate of duty will be Free.

Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 8536.90.8585, HTSUS, listed above.

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 China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8536.90.8585, HTSUS, listed above.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8536.90.8585, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8536.90.8585, HTSUS, listed above.

The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the Section 301 trade remedy, you may refer to the relevant parts of the USTR and CBP websites, which are available at:

https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china

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 Luke LePage at [email protected].
Sincerely,

(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division