The tariff classification of an LED light fixture from China

N261608 March 11, 2015 CLA-2-94:OT:RR:NC:N4:110 CATEGORY: Classification TARIFF NO.: 9405.40.6000 Ms. Paula Connelly Law Offices of Paula M. Connelly One Burlington Business Center 67 South Bedford St., Ste 400W Burlington, MA 01803 RE: The tariff classification of an LED light fixture from China Dear Ms. Connelly: In your letter dated February 10, 2015, on behalf of your client Digital Lumens, Inc., you requested a tariff classification ruling. The merchandise is identified as the Intelligent LED Linear Light Fixture (LLE3 and LLE6). Based on the information that you have provided, the item consists of an aluminum housing containing LED lamps, power supply, and driver with a lamp cover. The light fixture measures approximately 48 inches long by 4 inches tall by 3.7 inches deep. It is stated that the LED Linear Light Fixture can function alone or working together with the Digital Light Agent (imported separately) to perform additional functions such as dimming, light harvesting, etc. You have suggested a classification of 8543.70.7000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Electric luminescent lamps” and offered HQ H237734 as a substantiation.  However, this item is not an LED bulb/lamp as described in H237734 as it is more of a lighting fixture, complete with a housing, diffusing lens, and mounting fittings.  As such, classification in heading 8543 is not appropriate. The applicable subheading for the Intelligent LED Linear Light Fixture (LLE3 and LLE6), will be 9405.40.6000, HTSUS, which provides for “Lamps and lighting fittings…: Other electric lamps and lighting fittings: Of base metal: Other than of brass." The rate of duty will be 6 percent ad valorem. 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 Hope Abada at [email protected]. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division