CBP case study: why an LED light string is 'lamps and lighting' (9405), not a festive article (9505)
GRI 1Chapter 95 Note 1(t) (per HQ 953932)In CBP ruling N240754 a battery-powered LED light string — ten heart-shaped bulbs on a wire — was classified as lighting under HTS 9405.40.8000 (3.9% base duty), not as a festive article under heading 9505. The reason is a rule many importers miss: electric light strings and garlands are treated as lamps and lighting fittings, even when they are clearly decorative and holiday-themed.
It feels like a festive article — it is decorative, it is holiday-adjacent, and heading 9505 covers 'festive, carnival or other entertainment articles.' But Chapter 95 note 1(t) carves electric garlands 'of all kinds' out of Chapter 95 and sends them to heading 9405 (lamps and lighting fittings). So the moment a decoration becomes an electric light set, the festive heading 9505 is closed off and heading 9405 applies. CBP has applied this consistently — an electric light set imparts the essential character of a lighting article even when it wears jack-o'-lantern or heart-shaped covers (see HQ 953932 in the related section). One caveat on the exact code: the tariff schedule reorganized subheading 9405.40 in 2022, splitting out LED fittings, so the current 10-digit for an LED string today is likely within 9405.42 rather than the 9405.40.8000 shown in this 2013 ruling — verify the current subheading before you file.
- Do not file holiday light strings under 9505 (festive articles) just because they are decorative — electric light sets are excluded from Chapter 95 and belong in heading 9405. This is a very common error on seasonal goods.
- Verify the current 10-digit subheading before you enter: the schedule split 9405.40 in 2022, so an LED string today likely maps to 9405.42 rather than the 9405.40.8000 in this older ruling.
- Factor the lighting duty into your seasonal costing — a decoration can be duty-free as a festive article but becomes dutiable once it is an electric light set, so confirm the rate with your broker.
| Path | Code | Base duty |
|---|---|---|
| Heading CBP used (lighting) | 9405.40.8000 (today likely 9405.42) | 3.9% base |
| If it were a non-electric festive article illustrative | 9505.10.2500 | Free |
| The lights themselves change the duty. A non-electric holiday decoration — for example the artificial Christmas trees in ruling N319108 — can be duty-free under 9505.10.2500. Add an electric light set and you move to heading 9405 at 3.9%, roughly $1,950 on a $50,000 shipment where a festive-article classification would have been $0. For Chinese-origin goods, check the current Chapter 99 / Section 301 add-on on top of that. | ||
Illustrative comparison only. The alternative heading is one contrast possibility — the exact subheading for a different product configuration would need separate analysis (other Chapter 84/85 or specific provisions may apply). Any Section 301 / Chapter 99 figure assumes the goods remain subject to that measure at the time of entry; always verify the current Chapter 99 status and any applicable exclusions.
- Classifying seasonal electric light strings as festive articles (9505) is a frequent and easily-audited mistake — Chapter 95 note 1(t) excludes electric garlands, so the goods belong in 9405.
- Using an outdated 10-digit code matters: 9405.40 was restructured in 2022, and filing a superseded LED subheading can cause rejected entries or the wrong duty. Confirm the current subheading.
- The item is a decorated figure or ornament with no electric lighting → It can qualify as a festive article of heading 9505 (see the contrast ruling), which may be duty-free.
- The light string is mains-powered or uses a plug-in transformer instead of batteries → Still heading 9405 — the power source does not move it out of lighting; it remains an electric light set.
- It is specifically a Christmas-tree light set → Look at the dedicated lighting-set provisions within 9405 for that use; the festive heading 9505 still does not apply to electric light sets.
Seasonal lighting trips up a lot of importers: the product feels festive, so the festive heading feels right — but the chapter note quietly sends every electric garland to lighting instead. Two habits help: read the chapter's exclusion notes before trusting the 'obvious' heading, and re-check the exact 10-digit each season, since the lighting subheadings were reshuffled in 2022.
Are LED string lights classified as festive articles (9505) or lighting (9405)?
As lighting. Chapter 95 note 1(t) excludes electric garlands of all kinds from Chapter 95, so decorative electric light strings are classified in heading 9405 (lamps and lighting fittings). In ruling N240754 an LED light string was classified under 9405.40.8000. Note the subheading was reorganized in 2022 — verify the current 10-digit with a licensed customs broker.
Can holiday decorations be duty-free?
Some can. A non-electric festive article — such as the artificial Christmas trees in ruling N319108 — was classified under 9505.10.2500 duty-free. But once a decoration becomes an electric light set, it moves to heading 9405 and is dutiable. This is general information, not a classification determination.