exposed light
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 9405194020 | 38.9% | CN | US | Official Doc |
| 9405294010 | 38.7% | CN | US | Official Doc |
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AI Analysis
π‘ Exposed Light (Open-Frame Luminaires & Parts)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Strategy
π I. Product Definition & Classification: What is "Exposed Light"?
"Exposed Light" in international trade typically refers to luminaires and lighting fittings that are not enclosed in complex housing or are specifically designed for industrial, commercial, or decorative display purposes. Based on the provided data, the classification focuses on two specific categories:
- Chandeliers & Wall/Ceiling Fittings (Non-Public Use): Specifically those made of base metal (brass) and not intended for public spaces (like streets or parks).
- Table/Desk/Bedside/Floor Luminaires: Specifically Household items made of base metal (brass).
β οΈ Key Distinction Point:
- If the item is a Chandelier/Wall/Ceiling light made of brass for home/commercial interior use (not public thoroughfares) β HS 9405.19.40.20
- If the item is a Table/Desk/Floor lamp made of brass for Household use β HS 9405.29.40.10
π¦ II. HS Code Classification Details (2026 Tariff Authority Reference)
| HS Code | Product Description | Application Scenario | Material |
|---|---|---|---|
9405.19.40.20 |
Chandeliers and other electric ceiling or wall lighting fittings (Other: Of base metal: Of brass) | Indoor chandeliers, wall sconces, ceiling mounts for homes/offices (NOT public streets) | π₯ Brass (Base Metal) |
9405.29.40.10 |
Electric table, desk, bedside or floor-standing luminaires (Other: Of base metal: Of brass: Household) | Table lamps, desk lights, floor standing lamps for home use | π₯ Brass (Base Metal) |
π Critical Reminder:
- Both codes require the item to be made of Brass (a type of base metal).
- 9405.19.40.20 is for permanent fixtures (ceiling/wall).
- 9405.29.40.10 is for portable/household fixtures (table/floor/desk).
- "Exposed Light" implies open fixtures; ensure they are not "searchlights/spotlights" or "public lighting" to stay within these subheadings.
π° III. 2026 Latest Tariff Rate Details (Including Additional Taxes)
β Applicable Country: United States (US)
β Origin: China (CN) (Inferred from typical tariff structure provided)
β Effective Time: Current Trade Policy (Section 301 & IEEPA)
π― 1. 9405.19.40.20 ββ Brass Chandeliers/Wall Lights (Non-Public)
| Item | Content |
|---|---|
| Base Tariff | 3.9% (ad valorem) |
| Additional Tariff (Section 301) | +25.0% |
| Total Tariff Rate | 28.9% |
| Tax Calculation | CIF Value Γ 28.9% |
| De Minimis Exemption | β Not Applicable (High tariff threshold) |
| Legal Basis | HS 9405.19.40.20 β Section 301 List 4 / USITC Footnotes |
π Explanation:
- Base Rate (3.9%): Standard MFN (Most Favored Nation) rate for brass lighting fittings of this type.
- Additional Tariff (25.0%): Applied under U.S. Trade Act Section 301 against Chinese imports.
- Total Cost Impact: Nearly 29% of the CIF value is tax. This significantly impacts margin for brass lighting goods.
π― 2. 9405.29.40.10 ββ Brass Household Table/Floor Lamps
| Item | Content |
|---|---|
| Base Tariff | 3.7% (ad valorem) |
| Additional Tariff (Section 301) | +25.0% |
| Total Tariff Rate | 28.7% |
| Tax Calculation | CIF Value Γ 28.7% |
| De Minimis Exemption | β Not Applicable (High tariff threshold) |
| Legal Basis | HS 9405.29.40.10 β Section 301 List 4 / USITC Footnotes |
π Note:
- Slightly lower base rate (3.7% vs 3.9%) due to the "Household" designation for portable luminaires.
- The 25% additional tariff is identical, resulting in a 28.7% total.
- "Household" is key: If the lamp is for commercial/office use (non-household), the HS code may differ (e.g., 9405.29.40.90), potentially altering the tax profile.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Mandatory? | Description |
|---|---|---|
| β Product Specifications | βοΈ | Must specify Material: Brass (not just "metal"). |
| β Product Photos | βοΈ | Show light source type (LED/incandescent) and fixture style (chandelier vs. table lamp). |
| β Commercial Invoice | βοΈ | Clearly state: "Brass Chandelier for Indoor Residential Use" or "Brass Table Lamp, Household Use". |
| β Packing List | βοΈ | Detail any included bulbs, shades, or mounting hardware. |
| β Bill of Lading/Air Waybill | βοΈ | Standard shipping docs. |
| β Public Lighting Declaration | β | Do NOT claim it is for "Public Spaces" (e.g., street lights) for HS 9405.19.40.20, as it may lead to rejection or misclassification. |
β 2. Declaration Tips (Key Mnemonic)
π₯ "Brass Defines Code, Use Defines Subcode!"
| Scenario | Correct HS Code | Risk if Incorrect |
|---|---|---|
| Chandelier/Wall Light made of Brass for Home/Office (not streets) | 9405.19.40.20 (28.9%) |
If misdeclared as "Public Lighting" (9405.40) β Higher scrutiny, potential 12-15% base + 25% add'l. |
| Table/Floor Lamp made of Brass for Household use | 9405.29.40.10 (28.7%) |
If declared as "Commercial Lighting" β May fall under 9405.29.40.90 (28.7% or different base). |
| Made of Aluminum/Steel (Not Brass) | β Different HS Code | Do NOT use these codes. Brass is specific. If material is wrong, classification fails. |
| Contains Integrated LED (Non-replaceable) | Still 9405.1x or 9405.2x | Per the data: "having a permanently fixed light source" is included. |
β 3. Special Cases Handling
| Situation | Advice |
|---|---|
| OEM Custom Brass Lights | Provide design files and material certificates proving Brass composition. "Alloy" is too vague. |
| Mixed Materials (Brass + Glass) | The structural material (Brass) drives the classification under 9405.19/9405.29. |
| Lighting for Hotels (Non-Household) | If not "Household," table lamps may fall under general commercial lighting (9405.29.40.90), but still likely subject to 25% add'l tariff if Chinese. |
| Parts Only (Brass) | If importing only parts of chandeliers/lamps, check if they are "specifically designed" for 9405.1x/9405.2x. Otherwise, they may fall under 9405.99 (Parts), which may have different tax rates. |
π V. Global Market Comparison (2026 Snapshot)
| Market | Recommended HS Code | Base Tariff | Additional Tax | Total Impact |
|---|---|---|---|---|
| πΊπΈ USA | 9405.19.40.20 / 9405.29.40.10 |
3.7β3.9% | +25% | 28.7β28.9% |
| πͺπΊ EU | 9405.10 / 9405.29 | 0β6% | None | ~0β6% (Lowest) |
| π¨π³ China | 9405.10 / 9405.29 | 5β10% | None | ~5β10% |
| π¬π§ UK | 9405.10 / 9405.29 | 0β12% | None | ~0β12% |
π Conclusion:
- USA is the highest cost market due to the 25% Section 301 tariff.
- EU/UK/China have significantly lower total tariffs, making them more competitive for brass lighting exports.
- Strategy: If exporting to the US, consider cost-absorption or pricing adjustments to maintain margins.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Declaring Aluminum fixtures as Brass
π Consequence: Customs audit β Back taxes + penalties. Brass is denser and yellower; Aluminum is light and silver. Be precise.
β Mistake 2: Claiming Office Table Lamps as Household
π Consequence: Misclassification. If not for "Household," use 9405.29.40.90. While tax rate may be similar, description must match actual use.
β Mistake 3: Ignoring "Permanently Fixed Light Source"
π If the bulb is replaceable by the user, it is still a luminaire (9405). If it is a bulb-only (LED module), it may fall under 8539. Do not confuse.
β Mistake 4: Assuming De Minimis ($800) Applies
π Result: No! Section 301 tariffs are not exempt under de minimis. The 25% tax applies even to small shipments.
β Correct Practice:
"Brass Chandelier, Model XYZ, Indoor Use, Includes LED Drivers, Not for Public Outdoor Lighting"
"Brass Table Lamp, Household Use, Plug-in, LED Integrated"
π― VII. Conclusion: Professional Declaration, Cost Efficiency!
π― Remember the Golden Rules:
πΉ "Brass + Chandelier = 9405.19.40.20 (28.9%)"
πΉ "Brass + Table Lamp = 9405.29.40.10 (28.7%)"
πΉ "Household vs. Public vs. Commercial is the Key to Subcodes!"
π Tips:
- If your brass lighting is assembled in Vietnam/Malaysia, check for Certificate of Origin to potentially avoid US Section 301 tariffs.
- For large shipments, consider HS Code Pre-Ruling from US Customs (CBP) to lock in the classification and avoid audits.
π£ Immediate Action:
π Verify Material: Is it definitely Brass?
π Define Use: Household or Fixed Fixture?
π Calculate Landed Cost: Include 28.7β28.9% in your pricing!
β¨ Precision in Classification Saves Thousands!
πΌ Don't let tariff errors eat your profit margins!
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About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.