The tariff classification of an aviation headset part from the Philippines

N355393 November 10, 2025 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8518.90.8100, 9903.02.53 Madison Ratto Lightspeed Aviation 6135 Jean Road Lake Oswego, OR 97035 RE: The tariff classification of an aviation headset part from the Philippines Dear Ms. Ratto: In your letter dated October 29, 2025, you requested a tariff classification ruling. The item concerned is referred to as a strap cover, which is used in the production of Lightspeed’s Sierra Aviation Headset. The applicable SKU number is 250-00023-000.B2 - Assy, Strap Cover. This strap cover assembly is used in the production of the headband of the Sierra aviation headset. This rigid cover assembly aids in maintaining a secure fit, helps to provide consistent positioning of the headset, and provides comfort and structure when paired with soft headband pads. This part is made from ABS-PC - A thermoplastic blend of polycarbonate (PC) and acrylonitrile-butadiene- styrene (ABS). The applicable subheading for the strap cover assembly, SKU number is 250-00023-000.B2 - Assy, Strap Cover, will be 8518.90.8100, 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: Parts: Other: Other.” The general rate of duty will be Free. 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 the Philippines will be subject to an additional ad valorem rate of duty of 19 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.53, in addition to subheading 8518.90.8100, HTSUS, listed above. 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) Evan Conceicao Designated Official Performing the Duties of the Division Director National Commodity Specialist Division