NY N364722: RE: The tariff classification of electrical apparatus from Austria

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364722 September 25, 2026 CLA-2-94:OT:RR:NC:N4:410 CATEGORY: Classification TARIFF NO.: 9405.99.4090 Shanshan Liang Liang + Mooney, PLLC 2104 Delta Way, Unit 1 Tallahassee, FL 32303 RE: The tariff classification of electrical apparatus from Austria Dear Ms. Liang: In your letter dated August 31, 2026, you requested a classification ruling on behalf of Zumtobel Lighting GmbH. There are two items under consideration in this request, a current-carrying electrical support rail identified as material number 22169087, TECTON T 5 WH (Article 1) and an electrical feed-in module identified as material number 22169063, TECTON SF WH (Article 2). These items are tracks (referred to as “trunks”) of the TECTON lighting system which is endlessly customizable to the end user’s lighting design requirements and application. Article 1 is further described as the electrical and mechanical backbone or “trunk” of the TECTON lighting system and consists of an outer U-shaped steel housing, an inner U-shaped steel connection rail, polypropylene insulating conductor carriers, and copper conductors. The copper conductors extend along the entire length of the article providing a passive electrical connection function from one section of the “trunk” to another section of the “trunk”. Article 1 is mounted directly to the surface of a ceiling or wall or suspended pendant-style from a ceiling. We note that article 1 does not include any lamps, LED boards, reflectors, lenses, drivers, ballasts, or similar components that generate or direct light. It incorporates electrical wires, terminal blocks and circuit terminals. Article 2 is further described as a dedicated electrical feed-in module that accepts a power feed from electrical wiring and distributes that electricity through internal terminal blocks and multi-pin electrical connectors. Article 2 consists of an outer U-shaped steel housing, an inner U-shaped steel connection rail, multi-pole terminal blocks, polyamide electrical contact holders, multi-pin electrical connectors, a metal cover plate, a cable clip, fasteners, and other associated components. Article 2 connects to one end of the beginning section of article 1 distributing electrical power to that trunk section and on to subsequent sections of article 1 as per the design requirements of the end user.
In your request, you suggest that the correct classification of Articles 1 and 2 should be 8536.90.8585, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Subheading 8536.90.8585, HTSUS, is the basket provision for all other electrical apparatus not described or provided for elsewhere in subheading 8536, HTSUS. Based on the information provided, articles 1 and 2 are more accurately described as lighting tracks and components for track-style lighting as they provide both electrical and mechanical support for lighting fixtures and are akin to the goods described in CBP Ruling N233319, dated 10/2012. The applicable subheading for the TECTON T 5 WH (Article 1) and TECTON SF WH (Article 2) will be 9405.99.4090, HTSUS, which provides for "Lamps and lighting fittings…and parts thereof not elsewhere specified or included: Parts: Other: Other." The general rate of duty will be 6 percent ad valorem. The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact National Import Specialist Michael Chen at michael.w.chen@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division