Classification of Trailer Lighting Kit from Taiwan
Active· CBP ruling HQ 084654· Issued 1989-08-17
Ruling text
HQ 084654
August 17, 1989
CLA-2 CO:R:C:G 084654 TLS
CATEGORY: Classification
TARIFF NO.: 8512.20.2000
Ms. Gail Dembek
Blazer International Corporation
2960 Hart Drive
Franklin Park, Illinois 60131
RE: Classification of Trailer Lighting Kit from Taiwan
Dear Ms. Dembek:
Your letter of April 27, 1989 to our New York office requested
a ruling on the proper tariff classification of a trailer lighting
kit under the Harmonized Tariff Schedule of the United States
Annotated (HTSUSA). It has been referred to this office for reply.
FACTS:
The submitted sample is a trailer lighting kit, which consists
of the following: two red lens rear lights, two amber lens side
clearance lights, one plastic license plate bracket, connectors, and
the necessary hardware, wiring, and instructions for installation.
The entire kit is packaged to be sold as one complete unit. The
trailer lighting kit is used to provide lighting for car and truck
trailers when those trailers obstruct the view of the automobile's
standard lighting.
ISSUE:
Under which Harmonized Tariff Schedule of the United States
Annotated (HTSUSA) heading is the trailer lighting kit properly
classifiable:
1) 9405, HTSUSA, covering lamps and lighting fittings including
searchlights and spotlights and parts thereof, not elsewhere
specified or included; illuminated signs, illuminated nameplates and
the like, having a permanently fixed light source, and parts thereof
not elsewhere specified or included;
2) 8512, HTSUSA, covering electrical lighting or signaling equipment
(excluding articles of heading 8539), windshield wipers, defrosters
and demisters, of a kind used for cycles or motor vehicles; parts
thereof.
LAW AND ANALYSIS:
The General Rules of Interpretation (GRI) govern classification
of articles under the HTSUSA. GRI 1 requires us to classify goods
according to the terms of the headings and any relative section or
chapter notes. Heading 9405 provides for an article that is a lamp
or lighting fitting or a part thereof. The trailer lighting kit
consists of lighting fittings that operate as one unit, meeting the
description provided in 9405. We must refer to the notes of chapter
94 for additional guidance, however. Note (f) of chapter 94 states
that this chapter does not cover lamps or lighting fittings of
chapter 85.
Heading 8512 covers lighting equipment of a kind used for motor
vehicles and parts thereof. The trailer lighting kit is used as a
substitute for a vehicle's normal lighting when those lights are
obstructed by the trailer. The lights in this kit act as the
lighting equipment for the vehicle's rear and side when used in this
manner. This is within the terms required for classification under
heading 8512.
Both heading 9405 and 8512 provide for lighting equipment.
Heading 8512 must take precedence over heading 9405, however,
because note (f) of chapter 94 directs us to chapter 85 if an
article described under one of its headings is also described in a
heading under chapter 85. The trailer lighting kit is properly
classifiable under heading 8512.
HOLDING:
The trailer lighting kit is properly classified under
subheading 8512.20.2000, HTSUSA, covering other lighting equipment
of a kind used for motor vehicles.
Sincerely,
John Durant, Director
Source: rulings.cbp.gov — ruling 084654, retrieved 2026-10-12T05:18:37Z, republished verbatim. This digest is informational; only CBP issues binding rulings.