The tariff classification of an LED electrical properties tester from China

N355574 December 1, 2025 CLA-2-90:OT:RR:NC:CEE010:N1:105 CATEGORY: Classification TARIFF NO.: 9030.39.0100; 9903.01.24; 9903.01.25; 9903.88.01 Todd Karin Kiwa PVEL 388 Devlin Road Napa, CA 94558 RE: The tariff classification of an LED electrical properties tester from China Dear Mr. Karin: In your letter dated November 2, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The item under consideration is described as an LED electrical properties tester (model GSIV-22A), which is a sophisticated, software-controlled solar simulator designed to accurately replicate natural sunlight. It boasts a Class AAA rating for its spectral match, spatial uniformity, and temporal stability. The device utilizes an array of high-power LEDs to generate the AM1.5G solar spectrum, covering wavelengths between 350 and 1050 nm. Key features include instant-on capability, a long lifespan, energy efficiency, and precise control over individual LED wavelengths and total irradiance via user-friendly software. This makes it highly suitable for applications requiring consistent and controllable light, such as solar cell characterization, photocatalysis, and artificial photosynthesis. In operation, a user places a solar module inside the machine, connects electrical leads and temperature sensors, and then initiates a measurement after closing the doors. The LED lights activate, and an electronic load adjusts the current and voltage to acquire the solar module's current/voltage (I-V) characteristic. Optionally, the software can perform corrections for irradiance and temperature to estimate the electrical properties at standard test conditions (STC: 25°C, 1000 W/m²). Test results, including Amps, Volts, Watts, Watts/m², Ohms, and dimensionless quantities, are typically entered automatically into a database as graphs or raw numbers, though they can also be displayed on an integrated LCD screen. In a manufacturing setting, these measurements are crucial for determining the power class of a module, enabling sorting and proper labeling (e.g., modules measuring 495-500 W are labeled 500 W, and those measuring 500-505 W are labeled 505 W). In a solar test lab, the machine is used to assess device stability after environmental stress by comparing STC power measurements taken before and after stress. It also helps determine if a module meets its manufacturer’s power warranty by comparing measured STC power to the nameplate STC power. The light source and electrical readings are synchronized, allowing for triggered electrical measurements at various time delays after the light source activates. Additionally, the device can adjust temperature or irradiance to re-measure electrical properties under different test conditions, which is valuable for determining temperature coefficients of current and voltage, and low-light efficiency for device datasheets. In other uses, the temperature or irradiance are adjusted, and the device’s electrical properties are re-measured, which can determine the electrical properties at different test conditions. This type of measurement is useful for measuring the temperature coefficients of current and voltage, and low-light efficiency of the device, which is needed for the datasheet of the device. In your submission, you propose classification of the LED electrical properties tester (model GSIV-22A) in subheading 8486.20.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines and apparatus of a kind used solely or principally for the manufacture of semiconductor boules or wafers, semiconductor devices, electronic integrated circuits or flat panel displays; machines and apparatus specified in note 11(C) to this chapter; parts and accessories.” We disagree. Heading 8486 covers machines that are used solely or principally to manufacture, assemble, lift, handle, or load semiconductor devices and the like. The subject machine performs none of these functions; rather, it is used for conducting electric properties testing and measurements on photovoltaic modules after the modules are fully manufactured. In this regard, the Explanatory Notes to Heading 8486 state that the heading “excludes machines and apparatus for measuring, checking, inspecting, chemical analysis, etc.” Accordingly, the subject tester is precluded from classification in heading 8486. Additionally, we find the LED electrical properties tester primarily performs an electrical testing function that measures voltage, current, and resistance. While the device can also provide measurements for temperature (heading 9025) and light level (heading 9027), as well as providing the light itself, we find that heading 9030 captures the primary functionality. Accordingly, the applicable subheading for the LED electrical properties tester (model GSIV-22A) will be 9030.39.0100, HTSUS, which provides for “Oscilloscopes, spectrum analyzers and other instruments and apparatus for measuring or checking electrical quantities, excluding meters of heading 9028; instruments and apparatus for measuring or detecting alpha, beta, gamma, X-ray, cosmic or other ionizing radiations; parts and accessories thereof: Other instruments and apparatus, for measuring or checking voltage, current, resistance or power (other than those for measuring or checking semiconductor wafers or devices): Other, with a recording device.” 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 10 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 9030.39.0100, 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 9030.39.0100, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9030.39.0100, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 9030.39.0100, 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, 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/remedies/301-certain-products-china 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division