The tariff classification of a headphone assembly from the Philippines.

N360804
April 29, 2026
CLA-2-85:OT:RR:NC:N2: 209
CATEGORY: Classification
TARIFF NO.: 8518.30.2000
Madison Ratto Lightspeed Aviation 6135 Jean Road Lake Oswego, OR 97035 RE: The tariff classification of a headphone assembly from the Philippines. Dear Ms. Ratto: In your letter dated April 17, 2026, you requested a tariff classification ruling. The item concerned is referred to as “Assy, Headphone, Zulu H-MOD, 5-OHM Dyn. Mic, GA.” This is a modification kit/assembly which is intended to be installed within aviation helmets, forming a noise cancelling aviation headset. The applicable SKU number is 808-00003-001.1. This assembly consists of two ear cup speakers with microphones, electric cable harness, and a wired control box module. These items are imported as a complete and dedicated retrofit assembly, packaged together in a single importation. All components are imported simultaneously in the same package and are intended to be installed together within an aviation helmet. All of the items electrically connect to one another forming a functional aviation telecommunication headset. The applicable subheading for the “Assy, Headphone, Zulu H-MOD, 5-OHM Dyn. Mic, GA,” SKU number 808-00003-001.1 will be 8518.30.2000, 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: Headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers: 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