Rose Light

💡 Rose Lights (LED Chandeliers & Wall Fittings)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Strategic Classification for Decorative Lighting
📌 I. Product Definition & Classification: What Exactly is a "Rose Light"?

"Rose Light" typically refers to decorative lighting fixtures with floral, petal-like, or intricate geometric designs, often emitting a soft, ambient glow. In international trade, these are not classified by their aesthetic shape but by their light source technology, power source, and intended use.

For the scope of this guide, we focus on Household Electric Chandeliers and Wall Fittings designed exclusively for Light-Emitting Diode (LED) sources. These are distinct from traditional incandescent chandeliers or street lighting.

⚠️ Critical Distinction:
- If the light fixture is designed solely for LED sources → It falls under the specific LED sub-categories.
- If it is a general chandelier that can accept bulbs other than LEDs (e.g., E27 sockets for incandescent/CFL) → It may fall under a different "Other" category (see Note below).
- Exclusion: These are NOT for public spaces (streets, parks, airports). They are for household/private residential use.

📦 II. HS Code Classification Details (2026 Latest Tariff Authority)

Based on the provided data, there are two primary HS Codes for household LED decorative lighting fittings. The classification depends on whether the product is a specialized "LED-only" design or a more general "Other" category.

🔍 Key Insight for "Rose Lights":
- If your "Rose Light" has permanently fixed LED sources (like COB strips or fixed LED panels) and is made of metal, classify it as 9405.11.60.10.
- If it uses removable LED bulbs (e.g., GU10 LED bulbs) or has a non-metal frame (crystal, wood, plastic), it likely falls under 9405.19.80.10.
- Always check the material and socket type. "Rose" implies decorative, but the HS code is determined by technical specs.

💰 III. 2026 Latest Tariff Rate Breakdown (Detailed Tax Clauses)

✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Time: Current rates apply for imports from China.

🎯 1. 9405.11.60.10 — LED-Only Base Metal Chandeliers

📌 Explanation:
- 7.6% is the standard Most Favored Nation (MFN) duty for chandeliers.
- 25% is the additional duty imposed under the Section 301 Trade Action against Chinese goods. This is non-negotiable for Chinese-origin products.
- Total: 32.6%. This is a high-cost item. You cannot avoid this via de minimis (de minimis is excluded for Section 301 goods).

🎯 2. 9405.19.80.10 — Other Household Lighting Fittings

📌 Explanation:
- 3.9% is the standard MFN duty for "other" chandeliers/wall fittings.
- 25% is again the Section 301 additional duty.
- Total: 28.9%. Slightly lower than the LED-specific code, but still significant.

🛠️ IV. Customs Clearance Practical Advice (Pitfall Avoidance)

✅ 1. Documentation Checklist (Non-Negotiable)

✅ 2. Classification Strategy (The "Rose Light" Trap)

🔥 Pro Tip:
- If your "Rose Light" has screw-in sockets (even if currently sold with LEDs), Customs may argue it is NOT "designed solely for LED." In that case, you MUST use 9405.19.80.10 (28.9%), even if the product is technically LED-only.
- Documentation is Key: Your spec sheet must say "No replacement bulbs possible" or "Integrated LED Module" to justify the 32.6% code. If you can't prove it, they may default to the other code.

✅ 3. Special Considerations for "Rose Lights"

• Material Matters: If the frame is stainless steel, aluminum, or zinc alloy, it is "Base Metal." If it is glass, crystal, wood, or plastic, it does NOT fit 9405.11.60.10. It goes to 9405.19.80.10 (or other subcategories).
• "Rose" Design is Irrelevant to HS Code: Customs does not care about the shape. They care about:
• Is it a lighting fitting? (Yes)
• Is it for household use? (Yes)
• Is it LED-only? (Check design)
• Is it base metal? (Check material)

🌍 V. Global Market Comparison (2026)

📌 Conclusion:
- USA is the most expensive market due to the 25% Section 301 tariff.
- EU/Australia/China are significantly cheaper.
- If targeting the US, ensure your product is clearly documented as LED-only and base metal to avoid misclassification disputes.

📌 VI. Common Mistakes & Pitfalls

❌ Mistake 1: Calling it "Part of a Lamp" to avoid the 25% tariff.
👉 Consequence: Customs will reclassify it as a complete fitting → Back taxes + 25% penalty.

❌ Mistake 2: Assuming "Rose Light" means it's a decoration, not a light.
👉 Consequence: If it emits light, it's a lighting fitting. If it doesn't, it's 8302 or 7013. Misclassification leads to delays.

❌ Mistake 3: Using "LED" in the name but having removable sockets.
👉 Consequence: Must use 9405.19.80.10 (28.9%). Using 9405.11.60.10 (32.6%) is overpaying, but using 9405.11.60.10 for non-LED-only products is illegal misclassification.

✅ Correct Declaration Example:

"LED Chandelier, Model RL-2024, Base Metal, Integrated LED Module, 120V, Household Use, FCC Certified."

🎯 VII. Conclusion: Professional Classification Saves Money

🎯 Remember the Rule:

🔹 "Fixed LED + Base Metal = 9405.11.60.10 (32.6%)"
🔹 "General Household LED/Other = 9405.19.80.10 (28.9%)"
🔹 "No Light = Not HS 9405"

📌 Action Plan:
1. Verify Design: Is it truly LED-only? Are sockets fixed?
2. Check Material: Is it base metal?
3. Prepare Docs: Spec sheets, FCC, Photos.
4. Calculate Cost: Include 32.6% or 28.9% in your landed cost.
5. Avoid De Minimis: This is a high-value, high-duty category. Small shipments still pay full tariff.

✨ Professional Clearance Starts with Accurate Classification!
💼 Don't let "Rose" aesthetics hide the tariff reality!