RE: Applicability of partial duty exemption to lighting fixture components from China

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365356 October 22, 2026 CLA-2-98:OT:RR:NC:N4 410 CATEGORY: Classification TARIFF NO.: 9802.00.6000 Shanshan Liang Liang + Mooney, PLLC 2104 Delta Way, Unit 1 Tallahassee, FL 32303 RE: Applicability of partial duty exemption to lighting fixture components from China Dear Ms. Liang: In your letter dated September 23, 2026, on behalf of your client, TraStar, Inc. (“TraStar”), you requested an eligibility ruling for a partial duty exemption under subheading 9802.00.60, Harmonized Tariff Schedule of the United States (HTSUS). The merchandise covered by this request consists of four die-cast aluminum components used to construct TraStar’s street-light housing: (1) an Electrical Box; (2) an Electrical Box Cover; (3) a Lamp Housing; and (4) a Decorative Cover (collectively, the “Subject Merchandise. The Subject Merchandise is imported as semi-finished die castings. Each component requires specified U.S. metal-working operations before it can proceed to final assembly. TraStar will purchase aluminum ingots manufactured in the United States and will export those ingots to the Chinese processor for the production described below. TraStar will maintain supplier and production records establishing that the exported ingots were manufactured in the United States. The ingots will be exported without benefit of drawback. In China, the U.S.-manufactured aluminum ingots will be remelted and die-cast into the four Subject Merchandise components. The Chinese operation changes the ingots from primary metal forms into shaped street-light housing castings. The drilling, tapping/threading, and customer-specific machining operations described below will not be performed in China; those required features will be intentionally reserved for U.S. production after importation. For the proposed transaction, TraStar will require the Chinese processor to maintain records tracing the exported U.S. aluminum to the resulting casting batches and will not permit substitution of foreign aluminum for the exported U.S. aluminum. Process losses and scrap will be accounted for in the production records. After importation, TraStar will perform, or have performed in the United States, the following operations on the Subject Merchandise before final assembly. These operations include drilling and tapping/threading to create the mounting features required by the product specifications. The aluminum street-light housing components also undergo an additional procedure of powder coating. Only after the foregoing U.S. metal-working and coating operations are completed will the processed components proceed to final assembly with LEDs, drivers/electronics, wiring, lenses, gaskets, fasteners, and other components to form finished street lights. Subheading 9802.00.60, HTSUS, provides a partial duty exemption for: [a]ny article of metal . . . manufactured in the United States or subject to a process of manufacture in the United States, if exported for further processing, and if the exported article as processed outside the United States, or the article which results from the processing outside the United States, is returned to the United States for further processing. Subheading 9802.00.60, HTSUS, therefore imposes four requirements: (1) the merchandise must be an article of metal; (2) the metal must either be manufactured in the United States or subject to a process of manufacture in the United States; (3) the metal must be exported for further processing; and (4) the metal must be returned to the United States for further processing. For purposes of subheading 9802.00.60, HTSUS, “metal” includes “base metals enumerated in note 3 to section XV,” which in turn includes aluminum. Therefore, the aluminum ingots will qualify as an “article of metal” under subheading 9802.00.60, HTSUS, satisfying the first requirement. The aluminum ingots are of U.S. origin, satisfying the second requirement. The aluminum ingots are exported to China where they are remelted and die-cast. The conversion of aluminum ingots into various LED lighting fixture components changes the shape of the metal, preparing these components for the further processing in the U.S., satisfying the third requirement. Further, these components are returned to the U.S. where they will be drilled, tapped/threaded, and coated, and ultimately made into the finished merchandise constitutes “further processed” in the U.S., satisfying the fourth requirement. Consequently, we find that the Subject Merchandise will be eligible for a partial duty exemption under subheading 9802.00.60, HTSUS, when it is imported into the United States. The duty due will only be upon the value of the foreign processing, contingent upon compliance with the applicable regulations. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division