Chapter 85 covers electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles. This chapter is the main chapter in the HS classification for technology-intensive products, covering a wide range of goods from household appliances to industrial electronic equipment. The chapter notes provide clear definitions for semiconductor devices, integrated circuits, electric light sources, etc., and are the legal basis that must be focused on during classification. Heading 8539 includes various electric filament lamps, electric discharge lamps (including sealed beam lamp units and ultraviolet or infrared lamps), arc lamps, and light-emitting diode (LED) light sources. This heading covers not only traditional incandescent lamps and fluorescent lamps, but also explicitly includes LED bulbs and LED tubes. However, it should be noted that LED chips (unpackaged semiconductor devices) are classified under 8541, while complete luminaires fitted with LEDs may be classified under 9405. First 2 digits 85: indicates Chapter 85, i.e., electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles. Digits 3-4: 39 indicates heading 8539, specifically electric filament lamps, electric discharge lamps (including sealed beam lamp units and ultraviolet or infrared lamps), arc lamps, and light-emitting diode (LED) light sources. Digits 5-6: 50 indicates subheading 853950, i.e., light-emitting diode (LED) lamps. This subheading was newly added in the 2017 version of the HS, specifically to distinguish traditional incandescent and fluorescent lamps, reflecting the independent classification status of LED lighting products. This product is an LED light-emitting diode bulb, whose core function is lighting, and whose light source is LED. According to General Rules of Interpretation 1 and 6, it should be classified under heading 8539. Since LED bulbs are different from traditional incandescent lamps (8539.10) and fluorescent lamps (8539.31/32), and also different from LED chips (8541.40), they are classified under the dedicated subheading 853950. If it is an LED luminaire (such as a pendant lamp or desk lamp), it is classified under 9405.
Chapter
Chapter 85 covers electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles. This chapter is the main chapter in the HS classification for technology-intensive products, covering a wide range of goods from household appliances to industrial electronic equipment. The chapter notes provide clear definitions for semiconductor devices, integrated circuits, electric light sources, etc., and are the legal basis that must be focused on during classification.
Heading
Heading 8539 includes various electric filament lamps, electric discharge lamps (including sealed beam lamp units and ultraviolet or infrared lamps), arc lamps, and light-emitting diode (LED) light sources. This heading covers not only traditional incandescent lamps and fluorescent lamps, but also explicitly includes LED bulbs and LED tubes. However, it should be noted that LED chips (unpackaged semiconductor devices) are classified under 8541, while complete luminaires fitted with LEDs may be classified under 9405.
Digit Breakdown
First 2 digits 85: indicates Chapter 85, i.e., electrical machinery and equipment and parts thereof; sound recorders and reproducers, television image and sound recorders and reproducers, and parts and accessories of such articles. Digits 3-4: 39 indicates heading 8539, specifically electric filament lamps, electric discharge lamps (including sealed beam lamp units and ultraviolet or infrared lamps), arc lamps, and light-emitting diode (LED) light sources. Digits 5-6: 50 indicates subheading 853950, i.e., light-emitting diode (LED) lamps. This subheading was newly added in the 2017 version of the HS, specifically to distinguish traditional incandescent and fluorescent lamps, reflecting the independent classification status of LED lighting products.
Classification Basis
This product is an LED light-emitting diode bulb, whose core function is lighting, and whose light source is LED. According to General Rules of Interpretation 1 and 6, it should be classified under heading 8539. Since LED bulbs are different from traditional incandescent lamps (8539.10) and fluorescent lamps (8539.31/32), and also different from LED chips (8541.40), they are classified under the dedicated subheading 853950. If it is an LED luminaire (such as a pendant lamp or desk lamp), it is classified under 9405.
📝 Declaration Elements
Product Name: The Chinese and foreign-language name of the declared commodity should be specific and clear, such as "LED light-emitting diode bulb" rather than "LED lamp". Use: Explain the usage scenario of the bulb, such as indoor lighting, street lighting, decorative lighting, etc., which helps distinguish luminaires from light sources. Brand: Fill in the actual brand; if there is no brand, indicate "no brand" to avoid rejection of the declaration due to inaccurate brand declaration. Model: Fill in the model set by the manufacturer to identify specific specifications, such as E27-9W-6500K. Power: Declare the rated power of the bulb in watts (W), which affects classification and customs valuation. Base Type: Such as E27, E14, GU10, etc., which is the standard description of the bulb interface and affects classification and market access. Color Temperature: Expressed in Kelvin (K), such as 3000K, 6500K, reflecting the light color characteristics of the bulb. Contains Mercury: LED bulbs usually do not contain mercury, but this must be clearly declared to distinguish them from mercury-containing light sources such as fluorescent lamps. Product Name: LED light-emitting diode bulb; Use: indoor lighting; Brand: Philips; Model: 9290012345; Power: 9W; Base Type: E27; Color Temperature: 6500K; Contains Mercury: No; Packaging Specification: 10 pcs/box. Misreporting LED bulbs as LED luminaires, resulting in classification under 9405 instead of 8539. Failure to declare power or color temperature, affecting customs determination of product attributes. Inaccurate declaration of brand and model, which may trigger intellectual property or customs valuation risks.
Product Name
The Chinese and foreign-language name of the declared commodity should be specific and clear, such as "LED light-emitting diode bulb" rather than "LED lamp".
⚠️ Only writing "LED lamp" or "bulb", without reflecting the LED light source characteristics.
Use
Explain the usage scenario of the bulb, such as indoor lighting, street lighting, decorative lighting, etc., which helps distinguish luminaires from light sources.
⚠️ Vaguely writing "for lighting" without distinguishing the specific use.
Brand
Fill in the actual brand; if there is no brand, indicate "no brand" to avoid rejection of the declaration due to inaccurate brand declaration.
⚠️ The brand does not match the trademark, or the brand is omitted.
Model
Fill in the model set by the manufacturer to identify specific specifications, such as E27-9W-6500K.
⚠️ The model is incomplete or inconsistent with the actual product.
Power
Declare the rated power of the bulb in watts (W), which affects classification and customs valuation.
⚠️ Incorrect power unit (such as writing kW) or failure to declare.
Base Type
Such as E27, E14, GU10, etc., which is the standard description of the bulb interface and affects classification and market access.
⚠️ Incorrect description of the base type or use of non-standard terminology.
Color Temperature
Expressed in Kelvin (K), such as 3000K, 6500K, reflecting the light color characteristics of the bulb.
⚠️ The color temperature value does not match the actual product or is not declared.
Contains Mercury
LED bulbs usually do not contain mercury, but this must be clearly declared to distinguish them from mercury-containing light sources such as fluorescent lamps.
⚠️ Incorrectly declaring as containing mercury, resulting in classification under the fluorescent lamp subheading.
Example: Product Name: LED light-emitting diode bulb; Use: indoor lighting; Brand: Philips; Model: 9290012345; Power: 9W; Base Type: E27; Color Temperature: 6500K; Contains Mercury: No; Packaging Specification: 10 pcs/box.
Common Mistakes:
Misreporting LED bulbs as LED luminaires, resulting in classification under 9405 instead of 8539.
Failure to declare power or color temperature, affecting customs determination of product attributes.
Inaccurate declaration of brand and model, which may trigger intellectual property or customs valuation risks.
🎯 Classification Logic
The core basis for classification is the definition of heading 8539 in the Import and Export Tariff and the HS Explanatory Notes. As an electric light source, an LED bulb emits light through semiconductor light emission, which conforms to the description of subheading 853950. Note: if the bulb is combined with a base, housing, etc. to form a complete luminaire, it is classified under 9405; if it is an unpackaged LED chip, it is classified under 8541. In addition, according to General Rule of Interpretation 1, a bulb with an independent function should be classified first according to the terms of the heading. 853931 Fluorescent Tubes: Fluorescent lamps are gas-discharge light sources and contain mercury, while LED bulbs are semiconductor light sources and do not contain mercury. The two differ in light-emitting principle and structure, and must be distinguished by light source type during classification. 854140 Light-Emitting Diode Chips: 854140 covers unpackaged semiconductor devices, such as LED wafers and chips; 853950 covers packaged bulbs ready for direct use, with bases, drivers, etc. 940540 LED Luminaires: 9405 covers luminaires such as pendant lamps, desk lamps, and street lamps, usually including lamp holders, housings, brackets, etc.; 853950 covers only the bulb itself and does not include luminaire structures. 853929 Other Incandescent Lamps: 853929 covers incandescent lamps, which emit light by heating a filament; LED bulbs emit light through semiconductors, are more energy-efficient, and have a longer service life, and the two are in different subheadings. 853939 Other Discharge Lamps: 853939 includes other gas-discharge lamps, such as sodium lamps and metal halide lamps; LED bulbs are solid-state light sources and are not discharge lamps. Confirm whether the product is a complete bulb, rather than an LED chip or luminaire. Check whether the bulb contains mercury; if it contains mercury, it may be classified under the fluorescent lamp subheading. Check whether it has bulb characteristics such as a base and drive circuit. Confirm whether parameters such as power and color temperature are consistent with the declaration. Verify whether the brand and model are accurate to avoid infringement risks.
Basis
The core basis for classification is the definition of heading 8539 in the Import and Export Tariff and the HS Explanatory Notes. As an electric light source, an LED bulb emits light through semiconductor light emission, which conforms to the description of subheading 853950. Note: if the bulb is combined with a base, housing, etc. to form a complete luminaire, it is classified under 9405; if it is an unpackaged LED chip, it is classified under 8541. In addition, according to General Rule of Interpretation 1, a bulb with an independent function should be classified first according to the terms of the heading.
Confused Codes:
853931 - Fluorescent Tubes
Fluorescent lamps are gas-discharge light sources and contain mercury, while LED bulbs are semiconductor light sources and do not contain mercury. The two differ in light-emitting principle and structure, and must be distinguished by light source type during classification.
854140 - Light-Emitting Diode Chips
854140 covers unpackaged semiconductor devices, such as LED wafers and chips; 853950 covers packaged bulbs ready for direct use, with bases, drivers, etc.
940540 - LED Luminaires
9405 covers luminaires such as pendant lamps, desk lamps, and street lamps, usually including lamp holders, housings, brackets, etc.; 853950 covers only the bulb itself and does not include luminaire structures.
853929 - Other Incandescent Lamps
853929 covers incandescent lamps, which emit light by heating a filament; LED bulbs emit light through semiconductors, are more energy-efficient, and have a longer service life, and the two are in different subheadings.
853939 - Other Discharge Lamps
853939 includes other gas-discharge lamps, such as sodium lamps and metal halide lamps; LED bulbs are solid-state light sources and are not discharge lamps.
Self-Check:
✓ Confirm whether the product is a complete bulb, rather than an LED chip or luminaire.
✓ Check whether the bulb contains mercury; if it contains mercury, it may be classified under the fluorescent lamp subheading.
✓ Check whether it has bulb characteristics such as a base and drive circuit.
✓ Confirm whether parameters such as power and color temperature are consistent with the declaration.
✓ Verify whether the brand and model are accurate to avoid infringement risks.
❓ FAQ
How are LED bulbs and LED luminaires distinguished in HS codes? LED bulbs (853950) are independent light sources, usually with a standard base (such as E27), and can directly replace traditional bulbs. LED luminaires (9405) are complete lighting fixtures that include lamp holders, housings, brackets, etc., such as pendant lamps and desk lamps. If the product is only a bulb, classify it under 853950; if it is a complete luminaire containing a bulb, classify it under 9405. Is the HS code for LED bulbs globally uniform? The first 6 digits of the HS code (853950) are globally uniform in the Harmonized Commodity Description and Coding System, but countries may subdivide the last 4 digits. For example, China Customs' 10-digit code is 8539500000, while the U.S. HTSUS is 8539.50.00. For import and export, the complete code of the destination country's customs should prevail. When declaring LED bulbs, is an energy efficiency test report required? Some countries or regions have energy efficiency labeling requirements for LED bulbs, such as the EU ErP Directive and the U.S. Energy Star. Test reports are usually not required to be submitted directly during customs declaration, but customs may conduct spot checks, so it is advisable to prepare conformity certificates in advance. In addition, energy efficiency ratings may affect tariffs or market access. Do LED bulbs contain mercury? How should this be filled in during declaration? LED bulbs usually do not contain mercury, but during declaration it must be clearly filled in as "Contains Mercury: No". If incorrectly declared as containing mercury, it may result in classification under the fluorescent lamp subheading (853931), affecting tax rates and regulatory conditions. Mercury-containing bulbs must comply with environmental regulations such as the Minamata Convention on Mercury. How can I check the import tariff rate for LED bulbs? Tariff rates change with national policies and trade agreements. It is recommended to check the latest rates through the official website of the General Administration of Customs of China, the International Trade Single Window, or the destination country's customs website. At the same time, pay attention to preferential rates under free trade agreements (such as RCEP), which require a certificate of origin. Among the declaration elements for LED bulbs, are power and color temperature mandatory? Power and color temperature are important technical parameters of LED bulbs and help customs confirm product attributes and classification. Although some customs may not strictly require them, for smooth customs clearance it is recommended to declare them completely. If missing, supplementary information or inspection may be required. For cross-border e-commerce sales of LED bulbs, how should the HS code be selected? Cross-border e-commerce usually exports as small parcels, but if exported in bulk, correct classification is still required. LED bulbs should be classified under 853950. Note that if it is a set (such as bulb + base), it may be classified as a luminaire. It is recommended to consult a professional customs broker to ensure compliance. Has the HS code for LED bulbs changed in the 2022 version of the HS? The 2022 version of the HS did not make major adjustments to 8539, and subheading 853950 continues to be retained. However, countries may update their national subheadings. For example, in China's 2022 Tariff, 85395000 is subdivided into 8539500000. It is recommended to use the latest version of the tariff for inquiries.
Q: How are LED bulbs and LED luminaires distinguished in HS codes?
A: LED bulbs (853950) are independent light sources, usually with a standard base (such as E27), and can directly replace traditional bulbs. LED luminaires (9405) are complete lighting fixtures that include lamp holders, housings, brackets, etc., such as pendant lamps and desk lamps. If the product is only a bulb, classify it under 853950; if it is a complete luminaire containing a bulb, classify it under 9405.
Q: Is the HS code for LED bulbs globally uniform?
A: The first 6 digits of the HS code (853950) are globally uniform in the Harmonized Commodity Description and Coding System, but countries may subdivide the last 4 digits. For example, China Customs' 10-digit code is 8539500000, while the U.S. HTSUS is 8539.50.00. For import and export, the complete code of the destination country's customs should prevail.
Q: When declaring LED bulbs, is an energy efficiency test report required?
A: Some countries or regions have energy efficiency labeling requirements for LED bulbs, such as the EU ErP Directive and the U.S. Energy Star. Test reports are usually not required to be submitted directly during customs declaration, but customs may conduct spot checks, so it is advisable to prepare conformity certificates in advance. In addition, energy efficiency ratings may affect tariffs or market access.
Q: Do LED bulbs contain mercury? How should this be filled in during declaration?
A: LED bulbs usually do not contain mercury, but during declaration it must be clearly filled in as "Contains Mercury: No". If incorrectly declared as containing mercury, it may result in classification under the fluorescent lamp subheading (853931), affecting tax rates and regulatory conditions. Mercury-containing bulbs must comply with environmental regulations such as the Minamata Convention on Mercury.
Q: How can I check the import tariff rate for LED bulbs?
A: Tariff rates change with national policies and trade agreements. It is recommended to check the latest rates through the official website of the General Administration of Customs of China, the International Trade Single Window, or the destination country's customs website. At the same time, pay attention to preferential rates under free trade agreements (such as RCEP), which require a certificate of origin.
Q: Among the declaration elements for LED bulbs, are power and color temperature mandatory?
A: Power and color temperature are important technical parameters of LED bulbs and help customs confirm product attributes and classification. Although some customs may not strictly require them, for smooth customs clearance it is recommended to declare them completely. If missing, supplementary information or inspection may be required.
Q: For cross-border e-commerce sales of LED bulbs, how should the HS code be selected?
A: Cross-border e-commerce usually exports as small parcels, but if exported in bulk, correct classification is still required. LED bulbs should be classified under 853950. Note that if it is a set (such as bulb + base), it may be classified as a luminaire. It is recommended to consult a professional customs broker to ensure compliance.
Q: Has the HS code for LED bulbs changed in the 2022 version of the HS?
A: The 2022 version of the HS did not make major adjustments to 8539, and subheading 853950 continues to be retained. However, countries may update their national subheadings. For example, in China's 2022 Tariff, 85395000 is subdivided into 8539500000. It is recommended to use the latest version of the tariff for inquiries.
⚠️ Disclaimer: HS code classification, declaration elements, tariff rates and regulatory conditions on this page are for reference only and do not constitute legal advice on customs classification. Tariff rates and regulations are subject to change; the latest announcements from the General Administration of Customs and on-site determinations shall prevail. Please consult professional customs brokers or customs authorities before import/export.