The tariff classification of driver/speakers from China

N354004 October 1, 2025 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8518.29.8000, 9903.01.24, 9903.01.25, 9903.88.15 Madison Ratto Lightspeed Aviation 6135 Jean Road Lake Oswego, OR 97035 RE: The tariff classification of driver/speakers from China Dear Ms. Ratto: In your letter dated September 19, 2025, you requested a tariff classification ruling. The items concerned are driver/speaker assemblies used in the earcups of noise canceling aviation headsets. The first item concerned is a driver/speaker assembly used in the cups of the PFX aviation headset (model # 119-00002-100.A2). The function of the speaker/driver assembly is converting electrical signals into sound waves that can be heard by the user of the headset. The speaker/driver assembly consists of a voice coil (a coil of wire that receives the electrical audio signal), a magnet (creates a magnetic field that interacts with the voice coil), a diaphragm (a cone shaped membrane that moves to produce sound), suspension components (keeps the diaphragm centered and allows it to move back and forth). The second item concerned is a driver/speaker assembly used in the cups of the Sierra aviation headset (model # 119-00001-100.A1 ). The function of the speaker/driver assembly is converting electrical signals into sound waves that can be heard by the user of the headset. The speaker/driver assembly consists of a voice coil (a coil of wire that receives the electrical audio signal), a magnet (creates a magnetic field that interacts with the voice coil), a diaphragm (a cone shaped membrane that moves to produce sound), suspension components (keeps the diaphragm centered and allows it to move back and forth). Both models of driver/speaker operate at frequency between 200 Hz and 4000 Hz, and measure 48 mm in diameter. The applicable subheading for the both models of driver/speaker (model # 119-00002-100.A2 - PFX aviation headset, and model # 119-00001-100.A1 - Sierra aviation headset) will be 8518.29.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures…: Loudspeakers, whether or not mounted in their enclosures: Other: Other”. The general rate of duty will be Free. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition to subheading 8518.29.8000, HTSUS, listed above. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8518.29.8000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8518.29.8000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8518.29.8000, HTSUS, listed above. The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively. The tariffs and additional 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/. 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 steven.pollichino@cbp.dhs.gov. Sincerely, (for) Denise Faingar Designated Official Performing the Duties of the Division Director National Commodity Specialist Division