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 aviation headset insulator from China
Dear Ms. Ratto:
In your letter dated December 8, 2025, you requested a tariff classification ruling.
The item concerned is referred to as a Cup Insulator, SKU # 304-00007-000.A1. This item is a cut to shape
piece of Hypalon covered nylon. It is used inside the ear cups of Lightspeed’s Zulu 3 aviation headsets. Its
overall dimensions are 60 mm in length by 60 mm in width. Its shape resembles a cross.
The cup insulator helps control airflow and resonance inside the earcup. It creates a stable acoustic chamber,
which minimizes unwanted sound reflections and improves low-frequency noise attenuation. Hypalon’s
dense, non-resonant properties help dampen vibrations that could interfere with the active noise cancellation
system’s microphones and speakers. Hypalon is highly resistant to moisture, chemicals, and UV exposure,
which protects internal components from corrosion and degradation in harsh aviation environments. It also
adds a layer of fire resistance, meeting aviation safety standards. The insulator helps maintain the shape and
integrity of the earcup assembly, preventing movement of internal parts such as microphones, wiring, and
acoustic vents.
The applicable subheading for the Cup Insulator, SKU # 304-00007-000.A1.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