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 most core chapter of mechanical and electrical products in the HS classification, involving a wide range of commodities from household appliances to industrial electronic components. Headings within the chapter are arranged by function or use, such as 8501 electric motors, 8504 transformers, 8539 electric light sources, etc. Goods of this chapter generally have electrical or electronic operating principles, but attention must be paid to distinguishing them from mechanical apparatus of Chapter 84 and optical instruments of Chapter 90. Heading 8539 covers various electric light source products, including incandescent lamps, discharge lamps (such as fluorescent lamps, high-pressure sodium lamps), light-emitting diode (LED) lamps, and sealed beam lamps, etc. This heading includes not only complete bulbs and tubes but also their dedicated parts. However, if an LED tube has already constituted a luminaire (such as a complete lighting device with a bracket, housing, driver circuit, etc.), it may be classified under 9405. The core of 8539 is the electric light source itself, not the complete lighting fixture. Code 853951 is a 6-digit subheading. The first 2 digits 85 represent Chapter 85 (electrical machinery and equipment). Digits 3-4, 39, constitute heading 8539, referring to electric light source products. Digits 5-6, 51, are the subheading, specifically referring to light-emitting diode (LED) tubes. In the HS classification, 8539 is further subdivided: 8539.10 for sealed beam lamps, 8539.21 for tungsten filament lamps, 8539.31 for fluorescent lamps, 8539.41 for metal halide lamps, 8539.51 for light-emitting diode (LED) tubes, and 8539.52 for other light-emitting diode (LED) lamps. Therefore, 853951 specifically refers to LED tubes, distinguished from other LED lamps. This commodity is an LED tube, whose core function is to serve as an electric light source, emitting light using light-emitting diodes, and whose shape is tubular, conforming to the description of subheading 8539.51. It should not be classified under 8539.52 (other LED lamps), because the latter covers non-tubular LED bulbs or LED chips. It should also not be classified under 9405 (luminaire), because the LED tube itself is a light source and usually needs to be additionally installed into a luminaire, not constituting a complete luminaire. If the LED tube is assembled together with a bracket, driving power supply, etc. into one unit, it may be classified as a luminaire.
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 most core chapter of mechanical and electrical products in the HS classification, involving a wide range of commodities from household appliances to industrial electronic components. Headings within the chapter are arranged by function or use, such as 8501 electric motors, 8504 transformers, 8539 electric light sources, etc. Goods of this chapter generally have electrical or electronic operating principles, but attention must be paid to distinguishing them from mechanical apparatus of Chapter 84 and optical instruments of Chapter 90.
Heading
Heading 8539 covers various electric light source products, including incandescent lamps, discharge lamps (such as fluorescent lamps, high-pressure sodium lamps), light-emitting diode (LED) lamps, and sealed beam lamps, etc. This heading includes not only complete bulbs and tubes but also their dedicated parts. However, if an LED tube has already constituted a luminaire (such as a complete lighting device with a bracket, housing, driver circuit, etc.), it may be classified under 9405. The core of 8539 is the electric light source itself, not the complete lighting fixture.
Digit Breakdown
Code 853951 is a 6-digit subheading. The first 2 digits 85 represent Chapter 85 (electrical machinery and equipment). Digits 3-4, 39, constitute heading 8539, referring to electric light source products. Digits 5-6, 51, are the subheading, specifically referring to light-emitting diode (LED) tubes. In the HS classification, 8539 is further subdivided: 8539.10 for sealed beam lamps, 8539.21 for tungsten filament lamps, 8539.31 for fluorescent lamps, 8539.41 for metal halide lamps, 8539.51 for light-emitting diode (LED) tubes, and 8539.52 for other light-emitting diode (LED) lamps. Therefore, 853951 specifically refers to LED tubes, distinguished from other LED lamps.
Classification Basis
This commodity is an LED tube, whose core function is to serve as an electric light source, emitting light using light-emitting diodes, and whose shape is tubular, conforming to the description of subheading 8539.51. It should not be classified under 8539.52 (other LED lamps), because the latter covers non-tubular LED bulbs or LED chips. It should also not be classified under 9405 (luminaire), because the LED tube itself is a light source and usually needs to be additionally installed into a luminaire, not constituting a complete luminaire. If the LED tube is assembled together with a bracket, driving power supply, etc. into one unit, it may be classified as a luminaire.
📝 Declaration Elements
Product Name: The Chinese and English names of the declared commodity should accurately describe it as an LED tube, avoiding the use of vague terms such as tube or LED lamp. Use: Explain the main usage scenarios of the tube, such as indoor lighting, commercial lighting, industrial lighting, etc. Material: Describe the main materials of the tube, such as glass tube body, plastic end caps, aluminum substrate, etc. Brand: Declare the brand name of the tube; if there is no brand, fill in 'no brand'. Model: Fill in the specific model or specification code of the tube, such as T8-1200mm-18W. Power: Declare the rated power of the tube, in watts (W), such as 18W. Length: Declare the length of the tube, usually expressed in millimeters or feet, such as 1200mm or 4ft. Whether it contains a driver circuit: Explain whether the tube has a built-in driving power supply or requires an external driver. Product Name: LED tube; Use: indoor lighting; Material: glass tube body, plastic end caps; Brand: no brand; Model: T8-1200mm-18W; Power: 18W; Length: 1200mm; Whether it contains a driver circuit: built-in driver. Misreporting an LED tube as an LED bulb, resulting in a wrong subheading. Failing to distinguish whether it contains a driver circuit, which may affect classification. Incomplete filling of brand and model, resulting in inaccurate declaration.
Product Name
The Chinese and English names of the declared commodity should accurately describe it as an LED tube, avoiding the use of vague terms such as tube or LED lamp.
⚠️ Writing only tube or LED lamp without specifying the tubular form.
Use
Explain the main usage scenarios of the tube, such as indoor lighting, commercial lighting, industrial lighting, etc.
⚠️ Filling in 'for lighting' is too broad and not specific.
Material
Describe the main materials of the tube, such as glass tube body, plastic end caps, aluminum substrate, etc.
⚠️ Writing only plastic or glass without explaining the overall composition.
Brand
Declare the brand name of the tube; if there is no brand, fill in 'no brand'.
⚠️ Mistaking the manufacturer's name for the brand.
Model
Fill in the specific model or specification code of the tube, such as T8-1200mm-18W.
⚠️ Incomplete model filling or inconsistency with the actual product.
Power
Declare the rated power of the tube, in watts (W), such as 18W.
⚠️ Mistaking luminous flux or color temperature for power.
Length
Declare the length of the tube, usually expressed in millimeters or feet, such as 1200mm or 4ft.
⚠️ Not indicating the unit or using non-standard length descriptions.
Whether it contains a driver circuit
Explain whether the tube has a built-in driving power supply or requires an external driver.
⚠️ Confusing built-in driver with external driver, affecting classification.
Example： Product Name: LED tube; Use: indoor lighting; Material: glass tube body, plastic end caps; Brand: no brand; Model: T8-1200mm-18W; Power: 18W; Length: 1200mm; Whether it contains a driver circuit: built-in driver.
Common Mistakes：
Misreporting an LED tube as an LED bulb, resulting in a wrong subheading.
Failing to distinguish whether it contains a driver circuit, which may affect classification.
Incomplete filling of brand and model, resulting in inaccurate declaration.
🎯 Classification Logic
Core criteria for classification: First, confirm whether the commodity is an electric light source, i.e., a device that emits light using electrical energy. LED tubes meet this definition. Second, confirm that its form is tubular and that the light-emitting element is a light-emitting diode. According to HS notes, subheading 8539.51 specifically refers to LED tubes, regardless of length, power, or use. However, if the tube has been assembled with a luminaire housing, bracket, etc. into a complete luminaire, it should be classified as a luminaire under 9405. In addition, if the tube is an unencapsulated light source module, it may be classified under 8541 (semiconductor devices). Therefore, the key is whether the commodity has already constituted an electric light source listed under 8539. 853952 Other light-emitting diode lamps: 853952 covers non-tubular LED lamps, such as LED bulbs, LED spotlights, etc. The difference from 853951 lies in whether the shape is tubular. 940540 Other electric luminaires: 940540 covers complete luminaires, such as LED panel lights and LED batten lights. If an LED tube is integrated with a bracket, housing, etc., it is classified under 9405. 854140 Photosensitive semiconductor devices, light-emitting diodes: 854140 covers unencapsulated LED chips or simply encapsulated light source modules, whereas 853951 is a finished light source already made into a tube. 853931 Fluorescent lamps: 853931 is a hot-cathode fluorescent lamp, belonging to gas discharge lamps, and has a different light-emitting principle from LED tubes. Is the commodity a tubular LED light source? Has it already constituted a complete luminaire? Does it have a built-in driver circuit? Is it an unencapsulated light source module? Can it be classified under other subheadings of 8539?
Basis
Core criteria for classification: First, confirm whether the commodity is an electric light source, i.e., a device that emits light using electrical energy. LED tubes meet this definition. Second, confirm that its form is tubular and that the light-emitting element is a light-emitting diode. According to HS notes, subheading 8539.51 specifically refers to LED tubes, regardless of length, power, or use. However, if the tube has been assembled with a luminaire housing, bracket, etc. into a complete luminaire, it should be classified as a luminaire under 9405. In addition, if the tube is an unencapsulated light source module, it may be classified under 8541 (semiconductor devices). Therefore, the key is whether the commodity has already constituted an electric light source listed under 8539.
Confused Codes：
853952 - Other light-emitting diode lamps
853952 covers non-tubular LED lamps, such as LED bulbs, LED spotlights, etc. The difference from 853951 lies in whether the shape is tubular.
940540 - Other electric luminaires
940540 covers complete luminaires, such as LED panel lights and LED batten lights. If an LED tube is integrated with a bracket, housing, etc., it is classified under 9405.
854140 covers unencapsulated LED chips or simply encapsulated light source modules, whereas 853951 is a finished light source already made into a tube.
853931 - Fluorescent lamps
853931 is a hot-cathode fluorescent lamp, belonging to gas discharge lamps, and has a different light-emitting principle from LED tubes.
Self-Check：
✓ Is the commodity a tubular LED light source?
✓ Has it already constituted a complete luminaire?
✓ Does it have a built-in driver circuit?
✓ Is it an unencapsulated light source module?
✓ Can it be classified under other subheadings of 8539?
❓ FAQ
How to inquire about the HS code for LED tubes? You can check the customs tariff, HS code inquiry websites, or consult a customs broker. First determine that the commodity is an electric light source, then find heading 8539 according to form and light-emitting principle, and finally select subheading 853951 according to whether it is a tubular LED. What is the difference in HS codes between LED tubes and LED bulbs? LED tubes are classified under 853951, and LED bulbs under 853952. The difference lies in shape: tubular is a tube, other shapes are bulbs. The shape must be accurately described when declaring. If LED tubes are exported with brackets, which code should they be classified under? If the tube is assembled with a bracket, driving power supply, etc. into a complete luminaire, it should be classified under 9405 (luminaire). If it is only the tube itself and the bracket is packaged separately, the tube is classified under 853951, and the bracket is classified according to its material. When declaring LED tubes, are power and length mandatory? Yes, power and length are important declaration elements that help customs confirm the commodity attributes. Different power and length do not affect the HS code, but they must be declared truthfully. Does the driver circuit of an LED tube affect classification? If the driver circuit is built-in, it is still classified under 853951. If the driver circuit is external, the tube itself is still classified under 853951, but the driving power supply must be classified separately (such as 8504). Does classifying LED tubes under 853951 mean the tariff rate is fixed? No. The HS code is an internationally unified classification, but tariff rates are set by each country according to trade policy and may change. The latest tariff schedule of the importing country must be checked. How to distinguish 853951 from 854140? 853951 is a finished LED light source already made into a tube, which can be directly installed and used; 854140 is an unencapsulated LED chip or simply encapsulated light source module that needs further processing into a tube. What certifications should be noted when exporting LED tubes to the EU? Attention should be paid to CE certification, RoHS Directive, ERP energy efficiency labels, etc. HS code 853951 is the basis for customs declaration, but certification requirements must be separately confirmed according to EU regulations.
Q: How to inquire about the HS code for LED tubes?
A: You can check the customs tariff, HS code inquiry websites, or consult a customs broker. First determine that the commodity is an electric light source, then find heading 8539 according to form and light-emitting principle, and finally select subheading 853951 according to whether it is a tubular LED.
Q: What is the difference in HS codes between LED tubes and LED bulbs?
A: LED tubes are classified under 853951, and LED bulbs under 853952. The difference lies in shape: tubular is a tube, other shapes are bulbs. The shape must be accurately described when declaring.
Q: If LED tubes are exported with brackets, which code should they be classified under?
A: If the tube is assembled with a bracket, driving power supply, etc. into a complete luminaire, it should be classified under 9405 (luminaire). If it is only the tube itself and the bracket is packaged separately, the tube is classified under 853951, and the bracket is classified according to its material.
Q: When declaring LED tubes, are power and length mandatory?
A: Yes, power and length are important declaration elements that help customs confirm the commodity attributes. Different power and length do not affect the HS code, but they must be declared truthfully.
Q: Does the driver circuit of an LED tube affect classification?
A: If the driver circuit is built-in, it is still classified under 853951. If the driver circuit is external, the tube itself is still classified under 853951, but the driving power supply must be classified separately (such as 8504).
Q: Does classifying LED tubes under 853951 mean the tariff rate is fixed?
A: No. The HS code is an internationally unified classification, but tariff rates are set by each country according to trade policy and may change. The latest tariff schedule of the importing country must be checked.
Q: How to distinguish 853951 from 854140?
A: 853951 is a finished LED light source already made into a tube, which can be directly installed and used; 854140 is an unencapsulated LED chip or simply encapsulated light source module that needs further processing into a tube.
Q: What certifications should be noted when exporting LED tubes to the EU?
A: Attention should be paid to CE certification, RoHS Directive, ERP energy efficiency labels, etc. HS code 853951 is the basis for customs declaration, but certification requirements must be separately confirmed according to EU regulations.
⚠️ 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.