The tariff classification of an LED light bulb from Taiwan

N297843 June 29, 2018 CLA-2-85:OT:RR:NC:N4:410 CATEGORY: Classification TARIFF NO.: 8539.50.0090 Mr. Jimmy Ting Great World Customs Service 518 Eccles Ave. South San Francisco, CA 94080 RE: The tariff classification of an LED light bulb from Taiwan Dear Mr. Ting: In your letter dated June 13, 2018, on behalf of your client Leotek Electronics USA LLC, you requested a tariff classification ruling. The product under consideration is identified as LED Light Engines. You have stated that Leotek separately import the Light Engines as replacement light bulbs for their LED outdoor street lamps. The LED light bulbs are rectangular in shape and currently manufactured in three models: 4 LED, 20 LED, and 48 LED, which corresponds to the number of LEDs in the light bulbs. Each light bulb is comprised of multiple LED lamps, a PCB board, and a plastic lens - sometimes with a metal cover, a silicone layer, and a cable connector. The light bulbs are imported with all parts completely assembled into the units. The light bulbs are designed to be screwed onto the underside of a Leotek outdoor street lights. The cable connectors are then attached to the power supply inside the street lamps. Your request states you believe the Light Engines should be classified under heading 8541, Harmonized Tariff Schedule of the United States (HTSUS), applying GRI 3. However, Heading 8541, HTSUS, provides specifically for individual light-emitting diodes. In keeping with the common meaning of the term and the ENs, CBP has previously determined that the provision for LEDs in heading 8541, HTSUS, only covers individual LEDs (i.e., the semiconductor diodes without other components). (See, e.g., Headquarters Ruling Letter HQ H965524, dated August 29, 2002; HQ Ruling Letter H011693, dated December 18, 2007; HQ H010636, dated December 3, 2007; and HQ H003215, dated October 10, 2007). According to CBP administrative precedent, LEDs that have been incorporated into a lamp housing are beyond the scope of heading 8541, HTSUS. As such, it is CBP’s opinion that heading 8541, HTSUS, is not applicable to the assemblies concerned. The applicable subheading for the LED Light Engines, will be 8539.50.0090, HTSUS, which provides for “Electrical filament or discharge lamps…; Light-emitting diode (LED) lamps; Other.” The duty rate will be 2 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 https://hts.usitc.gov/current. 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 hope.abada@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division