The tariff classification of a light fixture from Hong Kong and China.

N099658 April 13, 2010 CLA-2-94:OT:RR:NC:1:110 CATEGORY: Classification TARIFF NO.: 9405.40.6000 Mr. Kenneth MacLure Digital Lumens 129 Portland Street, 4th Floor Boston, MA 02114 RE: The tariff classification of a light fixture from Hong Kong and China. Dear Mr. MacLure: In your letter dated March 31, 2010, you requested a tariff classification ruling. The merchandise under consideration is the ILE-HB-3. The ILE-HB-3 is an ultra-efficient light fixture designed to provide the maximum amount of light from the minimum amount of energy. It is targeted for industrial applications in a wide range of temperatures and environments. From the information you provided, the ILE-HB-3 measures approximately 4.2 inches high by 14.1 inches wide by 20.1 inches deep, and is comprised of an aluminum housing into which is installed three “light bars” and a smart power management unit (PMU) that combines power conversion technology with on-board processing. The light bars each consist of an array of 18 recessed LED (light emitting diode) lamps arranged in three 2 by 3 grids under individual plastic lenses. The PMU is the controller for the fixture, and contains the central processing unit, printed circuit board assemblies with various components, motion and light sensors, a wireless mesh-networking module, and a USB port. The latter two components allow the ILE-HB-3 to be connected to a personal computer for maintenance and configuration of the light fixture for maximum efficiency and precise light distribution. Flexible mounting and integrated electrical connectors permit the installation of the ILE-HB-3 virtually anywhere light is desired. In your ruling request you suggest classification of the ILE-HB-3 in 9405.40.8000, HTSUS, as an other electric lamp or lighting fitting of other than base metal. However, from the information you provided, the main structural component of the ILE-HB-3 is its aluminum housing. The applicable subheading for the ILE-HB-3 will be 9405.40.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Lamps and lighting fittings…: Other electric lamps and lighting fittings: Of base metal: Other.” The general 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 Thomas Campanelli at (646) 733-3016. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division