The tariff classification of an LED electrical properties tester from the Netherlands

N355766 December 3, 2025 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9030.39.0100; 9903.02.20 Todd Karin Kiwa PVEL 388 Devlin Road Napa, CA 94558 RE: The tariff classification of an LED electrical properties tester from the Netherlands Dear Mr. Karin: In your letter dated November 5, 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 LLS-XL), which functions as a high-performance solar simulator engineered for comprehensive evaluation of photovoltaic (PV) module performance and stability. This system is particularly adept at testing emerging technologies, including perovskite and tandem cells. Its core capability lies in accurately replicating natural sunlight’s intensity, spectrum, and uniformity within a controlled laboratory environment, and facilitating precise electrical (IV) measurements. Distinguishing itself from traditional xenon flash lamps, the LLS-XL utilizes an advanced LED light source to generate a broad and adjustable spectral range (typically 300-1200 nm), closely matching the AM1.5G solar spectrum. This spectral flexibility enables effective testing of diverse PV materials with varying sensitivities. Unlike transient flash simulators, the LLS-XL provides continuous, steady-state illumination for extended durations, which is crucial for long-term stability and degradation studies (light soaking) under consistent light and temperature conditions. Critical design considerations include ensuring high light uniformity across the test area (e.g., 50x50cm for mini-modules, scalable for full-size modules) and temporal stability over time. The system integrates seamlessly with a current-voltage (IV) measurement system, allowing for in-situ characterization while the sample is under illumination. Precise temperature control, typically ranging from 15°C to 85°C, is also incorporated. The system’s sophisticated software processes data from IV measurements and temperature sensors to determine key electrical properties of the solar module, such as maximum power output (Pmax), efficiency, open-circuit voltage (Voc), short-circuit current (Isc), and fill factor. The LLS-XL supports testing across a wide spectrum of PV technologies, including passivated emitter and rear cell (PERC), tunnel oxide passivated contact (TOPCon), heterojunction technology (HJT), interdigitated back contact (IBC), layered copper, indium, gallium and selenide (CIGS), cadmium telluride (CdTe), gallium arsenide (GaAs), perovskite, and tandem cells. It serves as an invaluable tool in both research and development laboratories for initial performance assessments and in manufacturing environments for long-term stability tests that simulate real-world conditions. Its precise temperature control further enables researchers to meticulously study the effects of temperature on module performance through temperature coefficient measurements. In your submission, you propose classification of the LED electrical properties tester (model LLS-XL) 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 LLS-XL) 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 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 European Union with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.20, in addition to subheading 9030.39.0100, 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 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