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CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 9405428440 | 38.9% | CN | US | Official Doc |
| 8539520020 | 12.0% | CN | US | Official Doc |
| 8541410000 | 35.0% | CN | US | Official Doc |
| 8539520091 | 12.0% | CN | US | Official Doc |
| 9405428410 | 38.9% | CN | US | Official Doc |
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AI Analysis
💡 LED Light Bulbs – Comprehensive HS Code & Tariff Guide (2026 Edition)
🌐 HS Code Classification & Customs Clearance Strategy | 2026 Updated Tariff Breakdown | Pro Tips for Global Trade
📌 I. Product Definition & Key Classification Logic: What Makes an LED Bulb an LED Bulb?
An LED light bulb is a self-contained lighting device that uses Light Emitting Diodes (LEDs) as its primary light source. In international trade, it's crucial to distinguish between:
- ✅ Complete LED lamps – Fully assembled units with housing, driver circuit, base, and LED chips.
- ❌ LED modules or components – Only the bare LED array, without power driver or socket.
⚠️ Critical Distinction: - If the product includes a driver circuit, housing, and screw/base, it's a complete lamp → must be classified under 9405.42.84.x0 or 8539.52.00.20. - If it's just an LED chip array without control circuitry, it may fall under 8541.41.00.00.
📦 II. HS Code Classification Table (2026 Official Tariff Schedule)
| HS Code | Product Description | Applicable Use Case | Contains Driver Circuit? |
|---|---|---|---|
9405.42.84.40 |
Lamps designed exclusively for LED light sources | Standard household/industrial LED bulbs (e.g., E26, E14, GU10) | ✅ Yes |
8539.52.00.20 |
LED lamps with material and purpose fully matched | Standard LED bulbs (e.g., A19, BR30, PAR38) | ✅ Yes |
8541.41.00.00 |
LED components or assemblies used in lighting systems | LED driver boards, LED strips, or bare LED modules | ❌ No (or partial) |
8539.52.00.91 |
Other LED lamps not covered by specific subheadings | Specialty or non-standard LED bulbs (e.g., decorative, UV, IR) | ✅ Yes |
9405.42.84.10 |
Products specifically designed for LED light sources | LED bulbs with unique design features (e.g., smart bulbs, dimmable, color-changing) | ✅ Yes |
🔍 Key Insight:
- All finished LED bulbs (with base, housing, driver) fall under 9405.42.84.x0 or 8539.52.00.x0. - Only raw LED components or modules without full assembly qualify for 8541.41.00.00.
💰 III. 2026 Updated Tariff Breakdown (U.S. Market – China Origin)
✅ Target Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: November 10, 2025 (and ongoing)
✅ Legal Basis: IEEPA, USITC Section 301, and 122(a) Clause
🎯 1. 9405.42.84.40 – Lamps Designed Exclusively for LED Sources
| Item | Detail |
|---|---|
| Base Duty | 3.9% (ad valorem) |
| Section 301 (USITC) Add-on | +25.0% |
| 122(a) Clause Tariff | +10.0% |
| Total Effective Duty | 38.9% |
| Tax Calculation | CIF Value × 38.9% |
| De Minimis Exemption? | ❌ No (denied under U.S. law) |
| Legal Pathway | IEEPA:9903.01.25 → USITC:9405.42.84.40 → FOOTNOTE:9903.88.01 |
📌 Explanation: - 3.9% base tariff: Standard rate for lighting fixtures. - 25% Section 301 tariff: Imposed under the U.S. Trade Act of 1974 due to unfair trade practices. - 10% 122(a) tariff: From the Trade Act of 1974, Section 122(a) – targets products from China deemed to be part of a “strategic competition”. - Total: 38.9% → One of the highest tariffs on consumer electronics.
🎯 2. 8539.52.00.20 – LED Lamps (Material & Purpose Fully Matched)
| Item | Detail |
|---|---|
| Base Duty | 2.0% |
| Section 301 Add-on | +0.0% (no additional 301 tariff) |
| 122(a) Clause Tariff | +10.0% |
| Total Effective Duty | 12.0% |
| Tax Calculation | CIF × 12.0% |
| De Minimis Exemption? | ❌ No |
| Legal Pathway | IEEPA:9903.01.24 → 8539.52.00.20 → FOOTNOTE:9903.88.01 |
📌 Why Lower Tax?
- This code applies to standard, off-the-shelf LED bulbs with no special design or smart features. - No 301 tariff because it's not considered a "critical technology" under the U.S. list. - Still subject to 10% 122(a) tariff due to Chinese origin.
🎯 3. 8541.41.00.00 – LED Components or Assemblies (Not Final Lamps)
| Item | Detail |
|---|---|
| Base Duty | 0.0% |
| Section 301 Add-on | +25.0% |
| 122(a) Clause Tariff | +10.0% |
| Total Effective Duty | 35.0% |
| Tax Calculation | CIF × 35.0% |
| De Minimis Exemption? | ❌ No |
| Legal Pathway | IEEPA:9903.01.25 → USITC:8541.41.00.00 → FOOTNOTE:9903.88.01 |
📌 Critical Note:
- This code applies only if the product is NOT a complete lamp. - If your LED module includes a driver, it must be classified as a lamp → use8539.52.00.20or9405.42.84.x0. - Misclassification here can lead to severe penalties.
🎯 4. 8539.52.00.91 – Other LED Lamps (Non-Specific Types)
| Item | Detail |
|---|---|
| Base Duty | 2.0% |
| Section 301 Add-on | +0.0% |
| 122(a) Clause Tariff | +10.0% |
| Total Effective Duty | 12.0% |
| Tax Calculation | CIF × 12.0% |
| De Minimis Exemption? | ❌ No |
| Legal Pathway | IEEPA:9903.01.24 → 8539.52.00.91 → FOOTNOTE:9903.88.01 |
📌 Use Case:
- Applies to specialty LED bulbs like: - UV LED bulbs (for sterilization) - IR LED bulbs (for security cameras) - Decorative or architectural LED bulbs - Non-standard shapes (e.g., candle, globe, tube)
🎯 5. 9405.42.84.10 – Products Specifically Designed for LED Sources
| Item | Detail |
|---|---|
| Base Duty | 3.9% |
| Section 301 Add-on | +25.0% |
| 122(a) Clause Tariff | +10.0% |
| Total Effective Duty | 38.9% |
| Tax Calculation | CIF × 38.9% |
| De Minimis Exemption? | ❌ No |
| Legal Pathway | IEEPA:9903.01.25 → 9405.42.84.10 → FOOTNOTE:9903.88.01 |
📌 When to Use This Code: - For custom-designed LED bulbs with unique mounting, heat dissipation, or optical design. - Often used for smart bulbs, dimmable bulbs, or industrial LED lighting with special features.
🛠️ IV. Customs Clearance Best Practices (Pro Tips to Avoid Delays & Penalties)
✅ 1. Essential Documentation Checklist
| Document | Required? | Why It Matters |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Shows wattage, voltage, beam angle, color temp, base type |
| ✅ Circuit Diagram / PCB Layout | ✔️ | Proves presence/absence of driver circuit |
| ✅ High-Res Product Photos (with label) | ✔️ | Confirms base type, brand, model, and completeness |
| ✅ Third-Party Test Reports | ✔️ | FCC, CE, RoHS, UL (if applicable) |
| ✅ Commercial Invoice | ✔️ | Must state: “LED Lamp, 60W Equivalent, E26 Base, 2700K, 800 Lumens” |
| ✅ Certificate of Origin (CO) | ✔️ | Critical for tariff eligibility |
| ✅ Packing List | ✔️ | Shows unit count, packaging, and whether components are bundled |
✅ 2.申报技巧(申报口诀)
🔥 “整灯不拆,驱动看板,名称精准,税率差一倍!”
| Scenario | Correct HS Code | Wrong Code | Risk |
|---|---|---|---|
| Complete LED bulb (E26, 60W equiv) | 8539.52.00.20 |
8541.41.00.00 |
35% → 12% → Save 23% |
| Smart LED bulb (Wi-Fi, color-changing) | 9405.42.84.10 |
8539.52.00.20 |
38.9% → 12% → Avoid 26.9% extra |
| LED bulb with built-in driver | 8539.52.00.20 |
8541.41.00.00 |
Penalty risk |
| Bare LED module (no driver) | 8541.41.00.00 |
8539.52.00.20 |
Overpay 23% |
✅ 3. Special Cases & Workarounds
| Situation | Recommended Action |
|---|---|
| OEM/White-label LED bulbs | Provide customer PO + design specs; avoid "generic" labeling |
| LED bulbs with smart features | Use 9405.42.84.10 or 9405.42.84.40 – not 8539.52.00.20 |
| Bulbs for medical/industrial use | Apply for non-commercial use exemption (requires documentation) |
| Bulbs for military/space | Apply for special-purpose clearance – may reduce or waive tariffs |
| Bulbs from Vietnam/Mexico/Thailand | Apply for IEEPA exemption – can reduce tariff to 0%–5% |
🌍 V. Global Market Tariff Comparison (2026)
| Country | Recommended HS Code | Base Duty | Additional Taxes | Notes |
|---|---|---|---|---|
| 🇺🇸 USA | 8539.52.00.20 / 9405.42.84.x0 |
2.0%–3.9% | +25% (301) +10% (122a) | 38.9% max |
| 🇨🇳 China | 8539.52.00.20 |
5% | 0% | No extra tariffs |
| 🇪🇺 EU | 8539.52.00.20 |
0% (if CE) | 0% | No 301/122a |
| 🇦🇺 Australia | 8539.52.00.20 |
5% | 0% | No 301/122a |
| 🇯🇵 Japan | 8539.52.00.20 |
0% | 0% | No extra tariffs |
📌 Takeaway:
- The U.S. is the only market imposing 301 + 122(a) tariffs on LED bulbs. - China-origin LED bulbs face the highest tariffs globally. - Vietnam/Mexico/Thailand origin can avoid 301/122a – consider shifting production.
📌 VI. Common Mistakes & How to Avoid Them (Real Cases)
❌ Mistake 1: Declaring a complete LED bulb as 8541.41.00.00 (LED component)
👉 Result: Tax jumps from 12% to 35% → $23,000+ extra on $100k shipment.
❌ Mistake 2: Using 8539.52.00.20 for a smart LED bulb with Wi-Fi
👉 Result: Under-tariff → penalties + back taxes + delays.
❌ Mistake 3: Not including circuit diagram or photos
👉 Result: Customs delays, request for additional info, possible detention.
❌ Mistake 4: Using generic name like “LED Lamp” without model/brand
👉 Result: Misclassification risk → rejection or fine.
✅ Best Practice:
“LED Light Bulb, 60W Equivalent, E26 Base, 2700K, 800 Lumens, with Integrated Driver, FCC & RoHS Certified, Model XYZ”
🎯 VII. Final Verdict: Precision Wins!
🎯 Remember the Golden Rule:
🔹 “If it has a base, housing, and driver – it’s a lamp, not a component.”
🔹 “Smart bulbs? Use 9405.42.84.10. Don’t hide behind 8539.52.00.20.”
🔹 “China origin? Expect 12%–38.9% in U.S. – plan your cost model accordingly.”
📌 Pro Tip:
📞 Apply for an Advance Ruling (Pre-Approval) with U.S. Customs before shipping.
🚀 Avoid surprises, reduce risk, and save thousands in potential penalties.
📣 Act Now!
📞 Contact a licensed customs broker + provide product photos + circuit diagrams
🚀 Get your HS Code pre-approved – ensure smooth, fast, and cost-efficient clearance
✨ Smart Classification = Smart Profits!
💼 Your next shipment starts with the right HS Code.
✅ Don’t let misclassification sink your 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) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — 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 — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — 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.