Published April 19, 2012 by

LED (Light Emitting Diode) Lamps / Bulps – Classification Revisited

Almost 2 1/2  years ago LawCustoms published an article dealing with classification of LED bulbs/lamps suggesting 8539.39.0000 classification based on N020620 (2007).  The interpretative methodology with respect to LED bulbs/lamps classification has evolved since the post‘s publication.  Since the LED lamp/bulb classification attracts the substantial amount of interest among LawCustoms guests, the author is revisiting the LED bulbs/lamps classification issue one more time. The classification departure point primarily took place in H024874 (2010), which extended GRI 2(a) principle to LED lamps/bulbs because they are LED Modules and therefore “comprise the light source of complete lamps.”  Id.  CBP reasoned that GRI 2(a) applies to LED modules because “when installed into housings adequate for their intended purpose, and connected to a power source by a power supply unit, they emit light.”  Id.  In H024876 (2010) CBP clarified what LED module is, stating that LED module may contain (1) printed circuit board, (2) light emitting diode, and (3) pin clasp.  In light of this development and the legal position that CBP is presumptively correct in classification determinations, trade community dealing with LED light bulbs/lamps will now have to extend the GRI 2(a) principle to the bulbs/lamps that contain the “module.”  Today, CBP GRI 2(a) method leaves trade community with two headings for LED light bulbs/lamps: 9405 and 8513.  For 8513 heading classification of lamps please see…

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Product Regulation U.S. Federal Agencies

Computers & Electronic Products Customs and Border Protection Electric Products Harmonized Tariff Schedule Classification HTS Heading 8513 HTS Heading 8539 HTS Heading 9405

Published June 1, 2009 by

LED lights

If one tries to bring LED light bulbs, she may rely on 8539.39.0000 classification based on N020620 (2007), which is presumptively valid 2.4% duty category. Mr. Campanelli, a CBP National Import Specialist who issued this ruling, said that LED bulbs belong neither to discharge, nor to electric filament category. This very issue is currently under review in CBP HQ, that leans toward the British interpretation of LED light emitting bulbs – 8543.70 (electrical apparatus, having individual functions n.e.s.o.i.). See in www.uktradeinfo.com for further information If this goes through, this would effectively raise the U.S. import duty by 0.2%

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Product Regulation U.S. Federal Agencies

Customs and Border Protection Electric Products Harmonized Tariff Schedule Classification HTS Heading 8539