CLA-2-85:OT:RR:NC:N1:112
Mr. B. Bahramian, President
Center for Technology Management, Inc.
2002 Halpine Walk Ct.
Rockville, MD 20851
RE: The tariff classification of LED bulbs from various countries
Dear Mr. Bahramian:
In your letter dated June 3, 2014, you requested a tariff classification ruling.
The items under consideration are parts of LED light bulbs that will be imported into the United States from various countries and assembled into the named “Elite LED Bulbs”. You state that all of the component parts detailed hereafter are molded, cut to shape, or otherwise fabricated so as to be used solely in the assembly of the Elite LED Bulb.
The “Housing for Internal Converters of Bulbs (Part #28.2)” is the stem body of the bulb that accommodates the integrated power supply and driver electronics, Bluetooth elements, USB connection, secondary power switch, and Edison screw base. The “DC Power Converter & USB circuitry (Part #28.3)” encompasses the power and driver electronics to be fitted into the housing base. The “LEDs Mounted on PCB (Part #29.3)” is a circular array of ten LED components mounted on a printed circuit board. The board will be attached to the driver electronics and 28.2 Housing and provide the illumination with the application of electrical power. The “LED Reflector Housing (Part #3.8.1)” is the cone shaped reflector body that screws into the 28.2 Housing. The reflector housing is made of either aluminum or plastic and has a polished interior. The “Acrylic Lenses (Part #3.8.2)” is the lens that will enclose the bulb. The lens will be imported cut to shape from clear plastic material, and will be fitted onto the 3.8.1 Reflective Housing cap upon assembly.
Once assembled, the finished product will be a LED bulb with an E27 base male socket, fitted with the integrated power and driver electronics to supply the LED board, and enclosed in plastic/aluminum reflector housing. The bulb will have secondary power inputs and control electronics to allow the bulb to sense a loss of 110 VAC and automatically switch over to 4 VDC, if connected. The intended application of the additional power inputs is to allow for a solar power supply to be used to power the light. Additionally, the bulb will contain Bluetooth technology to allow a user to turn the bulb off and on from a smart phone or other Bluetooth enabled control device.
The applicable subheading for the Housing Part #28.2, the Power & USB circuitry Part #28.3, the Reflector Housing Part #3.8.1, and the Acrylic Lenses Part #3.8.2 will be 8543.90.8880, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Parts: Other: Other: Other: Other.” The general rate of duty will be 2.6%.
The applicable subheading for the LED printed circuit board assembly Part #29.3 will be 8543.90.6800, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Parts: Other: Printed circuit assemblies: Other”. The general rate of duty will be 2.6%.
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 on World Wide Web at http://www.usitc.gov/tata/hts/.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Karl Moosbrugger at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division