HS Code for LED Street Lights: Classification Guide for Importers

A complete LED street light is classified as a luminaire, not as a light source. The Harmonized System is a multipurpose international product nomenclature developed by the World Customs Organization (WCO), comprising more than 5,000 commodity groups, each identified by a six-digit code, and used by more than 200 countries and economies as a basis for their customs tariffs.¹ For LED street lights, the deciding facts are whether the unit is a complete luminaire, whether it is photovoltaic, and whether it is designed for use solely with LED light sources. This guide covers classification only. The ordering steps are in how to import LED street lights from Bangladesh and the factory inspection points are in the LED street lights quality control checklist.

Quick answer: indicative HS heading (with verify note)

Heading 9405 covers luminaires and lighting fittings including searchlights and spotlights and parts thereof, not elsewhere specified or included, in the United States schedule.² Inside that heading, the other electric luminaires group splits by power source and light source design. Treat every code below as indicative and confirm the full national code for your exact model before filing.

The split between luminaire and light source is written into the chapter notes. Chapter 94 does not cover lamps or light sources and parts thereof of Chapter 85.² A complete street luminaire therefore stays in heading 9405, while a module or lamp sold separately leaves heading 9405 and goes to heading 8539. Keep complete luminaires, separate modules and separate lamps on separate invoice lines, each with its own code.

How HS codes are structured (2-4-6 digits)

The Harmonised System is organised in a hierarchical structure by sections, chapters of 2 digits, headings of 4 digits and sub-headings of 6 digits.⁵ Countries subdivide the six-digit categories further for their own tariffs, and the Combined Nomenclature of the European Union uses eight-digit codes.⁵ The current version is HS 2022.⁵

Only the first six digits are shared worldwide. The same street luminaire can carry a different full code in the United States, the European Union and the United Kingdom, even though 9405.41 or 9405.42 stays the same. Read the harmonized system explainer for the background on the system itself.

Factors that decide the code for LED street lights

Complete luminaire or separate light source. This is the first test, and it comes before wattage, optics or housing material. A street light shipped as a finished, working luminaire, with housing, optics, driver and LED module fitted, is classified in heading 9405. The same LED module shipped in a carton on its own is classified in heading 8539, because Chapter 94 expressly excludes lamps and light sources of Chapter 85.² A replacement module ordered as a spare part follows the module line, not the luminaire line of the street light it will be fitted into.

Photovoltaic or mains-powered. Inside the other electric luminaires group, the first split is power source. Subheading 9405.41 covers photovoltaic luminaires designed for use solely with LED light sources, and 9405.42 covers other luminaires designed for use solely with LED light sources.^{2 3} A solar street luminaire whose photovoltaic panel forms part of the luminaire as presented falls on the 9405.41 side, while a mains-powered street luminaire falls on the 9405.42 side. If the panel ships separately from the luminaire, classify the panel on its own line and do not assume the luminaire keeps the photovoltaic line.

Designed solely for LED light sources. Both 9405.41 and 9405.42 require the luminaire to be designed for use solely with LED light sources.² A street luminaire built for a discharge lamp, or for a mix of lamp types, does not meet that wording and falls to 9405.49, the other line inside the same group.^{2 3} Check the design, not the lamp fitted on the day.

Module or lamp, by the cap test. Heading 8539 covers electrical filament or discharge lamps, arc lamps, light-emitting diode (LED) light sources and parts thereof.⁴ Inside that heading, LED modules sit at 8539.51 and LED lamps at 8539.52.⁴ The Chapter 85 note draws the line by the cap: LED modules do not have a cap designed to allow easy installation or replacement in a luminaire, while LED lamps do have such a cap.⁴ A board-type LED engine without a cap is a module; a retrofit LED lamp with a cap is a lamp. The HS code for LED bulbs guide covers bulb-type sources in more depth.

Parts shipped separately. Parts of luminaires sit in the parts group of heading 9405, split by material into glass, plastics and other.² The United States schedule lists lampposts and bases for lampposts, of cast iron and of aluminium, inside the 9405.99 other-parts lines.² A pole or bracket shipped with the luminaire as part of the complete unit follows the luminaire; the same pole shipped on its own takes a parts line.

Searchlights and spotlights sit apart. The United Kingdom tariff separates searchlights and spotlights inside both 9405.41 and 9405.42, at 9405 4110 00 and 9405 4210 00.³ A unit built as a searchlight or spotlight therefore takes that line rather than the general other line. A standard road luminaire is not a searchlight, but a floodlight-type unit ordered for area lighting needs this check before it is filed as a street luminaire.

Heading terms and notes decide, at the same level. Classification is determined according to the terms of the headings and any relative section or chapter notes.³ For subheadings, classification is determined according to the terms of those subheadings and any related subheading notes, on the understanding that only subheadings at the same level are comparable.³ Compare 9405.41 against 9405.42, never against a national ten-digit line.

Material splits change the national code, not the six digits. At national level, the tariff splits further by material and form. The United Kingdom tariff splits the other lines into plastics and other materials, at 9405 4131 00 and 9405 4231 00 for plastics, and 9405 4139 90 and 9405 4239 90 for other materials.³ The United States schedule splits the same subheadings by base metal, with brass lines at 9405.41.40 and 9405.42.40 and other base metal lines at 9405.41.60 and 9405.42.60, plus other lines at 9405.41.84 and 9405.42.84.² Housing material therefore matters for the filed code even though it never changes 9405.41 or 9405.42.

National codes: US HTS, EU CN/TARIC, UK commodity code

United States: HTS, ten digits. For a complete LED street luminaire, start at 9405.41 for a photovoltaic model or 9405.42 for a mains-powered model, then read the material split: brass, other base metal, or other, at 9405.41.40, 9405.41.60 and 9405.41.84 for photovoltaic models, and 9405.42.40, 9405.42.60 and 9405.42.84 for other LED-only models.² A luminaire outside the LED-only lines sits at 9405.49.00.² Separate LED modules take 8539.51.00 and separate LED lamps take 8539.52.00.⁴ Read the full ten-digit line for your model and entry date in the current revision of the schedule.

European Union: CN at eight digits, TARIC for measures. The Combined Nomenclature of the European Union uses eight-digit codes, comprising the HS codes with further EU subdivisions and legal notes.⁵ The first six digits for a street luminaire are the same as everywhere else, 9405.41 or 9405.42, and the seventh and eighth digits add the EU subdivision. TARIC then adds further digits for measures that apply on the entry date. Read the confirmed line in TARIC for your model and entry date, and check the origin rules behind any preference claim before relying on it.

United Kingdom: commodity code, ten digits. The United Kingdom builds its commodity code on the same first six digits, with its own extension after them. The United Kingdom tariff lists, inside 9405.42, the plastics line at 9405 4231 00 and the other-materials lines at 9405 4239 10 and 9405 4239 90, and the Great Britain tariff confirms 9405 4239 90 as other, designed for use solely with LED light sources, other, other.^{3 6} Take the full code from the United Kingdom Trade Tariff for your luminaire and entry date, and do not copy a European Union eight-digit code onto a United Kingdom entry.

How to confirm the code officially

1. Write a precise description: complete luminaire or separate module or lamp, photovoltaic or mains-powered, designed solely for LED sources or not, housing material, and whether poles or brackets ship with the unit or separately.

2. Start from the official tariff for the destination: the USITC Harmonized Tariff Schedule, TARIC, or the United Kingdom Trade Tariff, and read the heading text and chapter notes before the code list.^{2 3}

3. Check published rulings for similar luminaires. For the United States, the USITC notes that the correct classification of many items can be found in the Customs Rulings Online Search Service (CROSS).⁷

4. For a borderline unit, such as a solar luminaire with a separately shipped panel or a floodlight-type unit near the searchlight line, apply for a binding decision before you ship. In the European Union, a Binding Tariff Information application needs a separate application for each type of product and a detailed description of the goods.⁸ In the United Kingdom, an Advance Tariff Ruling needs a GB EORI number and an intention to import into or export from Great Britain, and a legally binding decision is generally valid for 3 years.⁹ In the United States, if the merchandise is not described in any ruling on CROSS, you may request a binding ruling from United States Customs and Border Protection.⁷

5. Give your broker the description and the confirmed code for each line, and use the same codes across the invoice, packing list and entry. Read the how to classify your product guide alongside the tariff text when you work through the steps.

Common classification mistakes

Filing a complete luminaire under 8539. Heading 8539 is for light sources, not for finished luminaires.⁴ Chapter 94 excludes lamps and light sources of Chapter 85, so a complete street luminaire belongs in heading 9405 even though its light comes from LEDs.²

Filing a separate module or lamp under 9405. The reverse error is just as common. A module or lamp shipped on its own is a Chapter 85 good at 8539.51 or 8539.52, and the cap test in the Chapter 85 note decides between the two.⁴

Filing a solar and a mains-powered model on one line. The two models sit on different six-digit subheadings, 9405.41 and 9405.42.² One order with both types needs two lines and two codes.

Filing a non-LED-only luminaire as LED-only. Both 9405.41 and 9405.42 require the luminaire to be designed for use solely with LED light sources.² A luminaire designed for another lamp type falls to 9405.49, not to either LED-only line.

Filing poles and brackets on the luminaire line. Poles and brackets shipped separately are parts, inside the 9405.99 lines in the United States schedule.² Keep them off the luminaire subheading unless they ship as part of the complete unit.

Copying a code from another country. Only the first six digits are harmonised.⁵ The European Union extends them to eight digits,⁵ while the United States and the United Kingdom run to ten, with different material splits.^{2 3} A United States ten-digit code is not a United Kingdom commodity code.

Using a supplier catalogue code without checking it. A catalogue heading or a code from a neighbouring product is not a tariff decision. Read the heading text and chapter notes in the destination tariff, check rulings, and take a binding decision for a borderline unit.^{8 9 7}

Related duties and documents

This guide states no duty rates: the code decides which duty line customs applies, and a rate on a photovoltaic line does not carry to a mains-powered line, nor does a rate on a plastics line carry to a base metal line. Read the rate beside your confirmed code for your origin and entry date, and check what proof of origin a preference claim requires, since preferential treatment depends on meeting the rules of origin of the scheme.⁶

Keep the classification file with the shipment: the product description for each model, the confirmed code per line, any binding decision, and the origin evidence. Keep complete luminaires, separate modules, separate lamps and separately shipped poles on separate invoice lines that match their codes, so the entry, the packing list and the invoice agree line by line.

FAQs

What is the HS code for LED street lights?

A complete solar photovoltaic LED street luminaire sits at 9405.41 and a complete mains-powered LED street luminaire at 9405.42, both inside heading 9405 for luminaires and lighting fittings.² A complete luminaire not designed solely for LED sources sits at 9405.49.² Separate LED modules take 8539.51 and separate LED lamps take 8539.52.⁴ Confirm the full national code for your model before filing.

Is the HS code the same in every country?

Only the first six digits are the same. The Harmonised System is used by more than 200 countries and economies as a basis for their customs tariffs,¹ and countries subdivide the six-digit categories further for their own tariffs.⁵ The European Union uses eight-digit Combined Nomenclature codes,⁵ while the United States and the United Kingdom run to ten digits.^{2 6}

How do I confirm the correct code?

Describe the product precisely, read the heading text and chapter notes in the destination tariff, and check published rulings such as CROSS for the United States.⁷ For a borderline unit, apply for a binding decision before shipping: a Binding Tariff Information decision in the European Union,⁸ an Advance Tariff Ruling in the United Kingdom,⁹ or a binding ruling from United States Customs and Border Protection.⁷

What happens if I use the wrong code?

Duty, licensing and quota treatment are worked out from the code on the declaration, so a wrong code brings the wrong treatment. A legally binding decision helps calculate customs duties, licensing requirements, quotas and other restrictions in advance.⁹ Correct the code with your broker before the entry is filed, and keep the corrected code consistent across every document.

Next steps on Exportain

Browse Bangladeshi suppliers on Exportain and post a free RFQ at Exportain RFQs with the confirmed code stated per line, so quotes are compared on the same classification. Then read how to import LED street lights from Bangladesh for the ordering steps and the LED street lights quality control checklist for the factory checks. Exportain is not a party to the goods contract and does not inspect goods, book freight or clear customs, so keep your broker and your binding decision at the centre of the entry.