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 wiring assembly with PCBA from China
Dear Ms. Ratto:
In your letter dated April 26, 2026, you requested a tariff classification ruling.
The item concerned is referred to as the “H-Mod CEP Kit,” SKU # 807-00034-001.A2. This item is an
electrical wiring assembly which consists of two insulated wires, a printed circuit board assembly and
electrical connectors. This assembly is used in the production of aviation headsets which are installed within
aviation helmets. The CEP Kit routes intercom and radio audio signals from the helmet’s internal
communication wiring—feeding the ear-cup speakers—into a communication ear plug kit which consists of
miniature transducers worn in the pilot’s ear canal. The item concerned incorporates a voltage divider or
attenuation network, facilitates proper impedance matching, and amplifies the incoming signal from the
headset to the in ear transducers.
The applicable subheading for the “H-Mod CEP Kit,” SKU # 807-00034-001.A2 will be 8517.62.0090,
Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including
smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the
transmission or reception of voice, images or other data, including apparatus for communication in a wired or
wireless network (such as a local or wide area network)…: Other apparatus for transmission or reception of
voice, images or other data, including apparatus for communication in a wired or wireless network (such as a
local or wide area network): Machines for the reception, conversion and transmission or regeneration of
voice, images or other data, including switching and routing apparatus: 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 the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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)
James P. Forkan
Director
National Commodity Specialist Division