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LED Lights HS Code and US Duty Rate: 9405 Luminaires vs 8539 LED Lamps

Updated 2026-10-19. Every figure below is recomputed at build time from the official USITC HTS export and our Chapter 99 census; provenance notes are embedded in the page source.

1. Why LED lights live in two headings

Importers search for “the HS code for LED lights” as if one code existed. It never does, and for lighting the ambiguity is unusually expensive because the two candidate headings disagree on purpose. Heading 9405 covers lamps and lighting fittings as apparatus: chandeliers, ceiling or wall fittings, portable desk and floor lamps, Christmas sets, signage-lit structures — the whole assembled object whose function is to illuminate a space. Heading 8539 covers the light sources themselves: the replaceable bulbs, tubes and lamps you screw or clip into something else. Under 8539.52.00 the schedule says so in plain words: “Light-emitting diode (LED) lamps” — and all 7 ten-digit statistical lines of that provision sit inside a single eight-digit family.

The boundary question — is an LED strip, module or panel a fitting or a lamp? — is one of the most litigated classification puzzles in modern electronics, and the answer changes the money: the 9405 families we census below run from 2.9% to 12.0% general rate, while bare LED lamps sit at 2.0%. A factor of six separates the cheap end of 9405 from 8539.52.00 before any trade-action stack. For how the schedule's own wording resolves disputes like this, see the official HTS interface, whose REST export feeds every number on this page.

2. The 9405 side: 76 statistical lines, 39 eight-digit families

We parsed the current schedule and counted every line beginning 9405: 76 tariff lines, of which 58 are ten-digit statistical breakouts carrying their own two-digit suffix, grouping into 39 distinct eight-digit families. 37 of the 39 families charge a pure percentage general rate spanning 2.9% to 12.0%; the remaining families are duty-free niches such as the LED backlight-module provision discussed below. The rate extremes are instructive. The cheapest dutiful corner is 9405.50.20 (2.9%, incandescent luminaires designed to operate on propane) and the dearest are the parts lines 9405.91.10, 9405.91.30 at 12.0% — note that parts of luminaires can cost more than the finished fittings, a classic trap when you ship spare glassware or housings alongside a fixture order.

Brass drives the most common split. Ceiling and wall fittings of brass pay 3.9% while otherwise-identical fittings of other materials pay 7.6% — nearly double. Christmas-style LED lighting sets designed solely for LED light sources (9405.31.00) pay 8.0%. On the preference side, 74 of the 76 ten-digit lines open with “Free (A*…)” in the Special column, so eligible FTA origins routinely land duty-free under 9405; the practical work is proving origin, not arguing classification. Where your product sits inside the family tree matters too, because the last two digits select the statistical breakout — our ten-digit statistical suffix guide walks that mechanic.

3. Decision table: which heading owns your product

Rates recomputed from data/hts.json (vintage 2026-10-19T13:27:57Z); the §301 column reflects our Chapter 99 census retrieved 2026-10-16T13:26:26Z.

Three boundaries cause nearly all the disputes. First, complete fixtures vs replacement sources: if the item illuminates a space as installed apparatus, it is 9405; if it is the swappable source, 8539. Second, LED strips and modules: flexible PCB-mounted LED strip sold on rolls generally behaves like a component — but LED backlight modules built on a substrate for LCD illumination get their own carved-out provision at 9405.42.82.00, currently Free, precisely because Congress and the committee wanted display supply chains treated differently. Third, sets put up for retail: a boxed kit of LED sources plus controller can travel with the fittings under 9405.31.00 at 8.0%. When the facts sit near a boundary, the schedule's General Rules of Interpretation push you toward the heading with the more specific description — and when two readings survive that test, the duty question is worth a binding ruling before the first container ships. The arithmetic of multi-leg rates that follow is covered in our specific and compound tariff arithmetic walkthrough.

4. The Section 301 stack that punishes the wrong heading

Since 2018 the decisive layer for China-origin goods is Section 301. Our Chapter 99 census — parsed from the official Chapter 99 provisions with source URL and capture timestamp recorded per row — shows the asymmetry starkly:

• Heading 9405: 39 of 39 eight-digit families covered, every one at 25% under action 9903.88.03. There is effectively no 9405 refuge from the China stack.
• Heading 8539: 11 eight-digit families covered (halogen filaments, discharge lamps, arc lamps and parts) — but 8539.52.00 LED lamps are not among them as of the census date. The bare-LED-lamp heading escapes the listing in our data.

That asymmetry is why the classification question is a money question. Consider a 20,000-dollar invoice of Chinese LED lighting sets classified correctly under 9405.31.00: the MFN leg is 8.0% = $1,600, the Section 301 action adds 25% = $5,000, for a combined 33.0% effective burden of $6,600. The same invoice argued into 8539.52.00 pays 2.0% = $400 and no 301 listing — a spread of $6,200 on one pallet-space-heavy shipment. The gap explains why CBP periodically audits lighting entries, and why under-deposits surface with interest at liquidation. Price both scenarios before committing to a selling price with the landed-cost duty calculator, and track the expensive end of the schedule with our full census of the highest US tariff lines.

Two caveats keep the math honest. Column 2 rates — the statutory non-WTO tier — run 20% for LED lamps up to 50% for LED sets, so country of normal trade relations status matters as much as the classification argument. And trade actions move: the 301 census is refreshed from the Chapter 99 provisions on a rolling basis, so re-verify both headings' stack status at quoting time rather than relying on a competitor's blog post from last quarter.

5. Playbook: five checks before you book the shipment

1. Write down what the article physically does. Illuminate a space as installed apparatus → 9405. Serve as the replaceable source → 8539. Sell both? They are different entries, possibly in one box.
2. Find the exact eight-digit family, not the heading. Brass vs other (3.9% vs 7.6%) and sets vs portables (8.0% vs 3.9%) live one digit apart. Our HS heading 9405 page keeps the family tree browsable.
3. Check the Free-carve-outs. LED backlight modules (9405.42.82.00) ride Free — if your LCD-backlight business is paying duty there, someone guessed instead of reading the provision.
4. Stack the trade actions. MFN 8.0% is not the paid rate for China origin; add the 25-point action. Compare against the broader pattern in our US tariff rates by product category.
5. Get borderline calls ruled. An LED module that could be 9405 or 8539 is exactly what CBP binding rulings are for — request one before the entry, not after liquidation.

6. Frequently asked questions

1. What is the HS code for LED lights?

There is no single one. Finished luminaires and lighting sets classify in heading 9405; bare LED lamps and replacement bulbs classify in 8539.52.00, which carries a 2% US general rate. The product's form and function — not the presence of LEDs — picks the heading.

2. What is the US duty rate on LED lights?

It ranges widely: the 9405 families we census run from 2.9% to 12% general rate with most luminaires near 4-8%, while bare LED lamps under 8539.52.00 sit at 2%. Column 2 rates range from 20% (LED lamps) up to 50% (LED lighting sets).

3. Does Section 301 apply to LED lights from China?

For heading 9405 yes, essentially everywhere: all 39 eight-digit families are covered by action 9903.88.03 at 25% in our Chapter 99 census. Bare LED lamps under 8539.52.00 were not listed in the same census as of its retrieval date, which makes the classification decision even more valuable for China-origin shipments.

4. Why does it matter whether my product is a luminaire or a lamp?

Because the two headings differ by more than the MFN rate. On a $20,000 Chinese shipment classified as an LED lighting set (9405.31.00), the MFN leg alone is $1,600 and Section 301 adds another $5,000; the same invoice classified as a bare LED lamp (8539.52.00) owes $400 with no 301 listing. Misclassification cuts both ways: CBP can collect the difference plus interest at liquidation.

5. How do I know which heading applies to my product?

Apply the heading texts and the General Rules of Interpretation: if the article is a lighting apparatus complete with its housing, wiring and switch, it is a luminaire (9405). If it is the light source itself — a bulb or tube that screws, clips or plugs into something else — it belongs to 8539. Borderline LED modules and strips deserve a binding ruling from CBP before you commit.

6. How was this article's data produced?

Every figure is recomputed at build time from our local copy of the official USITC Harmonized Tariff Schedule REST export and our Chapter 99 Section 301 census, each stored with source URL and capture timestamp. The build fails loudly if any pinned headline figure moves after a quarterly data refresh.

7. Recap

• LED products split between 9405 luminaires/sets and 8539.52.00 bare LED lamps; the schedule's own wording, not the presence of LEDs, picks the heading.
• Across 39 eight-digit 9405 families the general rate spans 2.9%–12.0%; bare LED lamps pay 2.0% with a 20% Column 2 ceiling.
• From China, 39/39 9405 families stack a 25-point Section 301 action; LED lamps were not listed in our census — a 33.0% vs 2% swing on the worked example.
• Classification errors on lighting are recoverable but expensive; the playbook's five checks plus a binding ruling on genuinely borderline items keep the exposure bounded.