The tariff classification of aviation headsets from the Philippines

N356067 December 10, 2025 CLA-2-85:OT:RR:NC:N2 209 CATEGORY: Classification TARIFF NO.: 8518.30.2000; 9903.02.53 Madison Ratto Lightspeed Aviation 6135 Jean Road Lake Oswego, OR 97035 RE: The tariff classification of aviation headsets from the Philippines Dear Ms. Ratto: In your letter dated November 16, 2025, you requested a tariff classification ruling. There are three items at issue with this request, which are all described as aviation headsets. The subject headsets are individually identified by model numbers 800-00025-001.A1 (Zulu), 800-00001-000.A10 (Sierra), and 800-00019-001.A9 (Zulu 3). They are all comprised of a robust headband that connects two large earcups (speakers) and a boom microphone attached to the left earcup. The headsets feature an upper cable that connects the control box from the headset and a lower cable that connects from the control box to the instrument panel of the aircraft. The control box is a controller module with power indicator, power button, and volume control/button, allowing the user to control various functions of the headset. All three models are similar in features and function, but they differ in the shape and size of the earcups, and the materials used. In use, the headsets are connected to the instrument panel or intercom of an aircraft allowing the pilot and passengers to communicate during flight as the noise inside the cockpit can rise to excessive levels. The headsets provide noise cancellation for the pilot and passengers to be able to communicate clearly within the cockpit as well as with air traffic control. The applicable subheading for the aviation headsets, model numbers 800-00025-001.A1 (Zulu), 800-00001-000.A10 (Sierra), and 800-00019-001.A9 (Zulu 3) will be 8518.30.2000, 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: Headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers: 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 8518.30.2000, 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) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division