Chapter Overview
Chapter 85 of the HTS is one of the broadest and highest-value chapters in U.S. import trade. It covers electrical machinery and equipment, including electric motors, generators, transformers, batteries and accumulators, power supplies, audio and video equipment, televisions, monitors, speakers, wiring, connectors, LEDs, and semiconductors. The United States imports hundreds of billions of dollars in Chapter 85 products annually.
For consumer electronics importers and DTC brands, the most commonly used headings include 8507 (batteries and accumulators, especially lithium-ion), 8504 (transformers, static converters, chargers), 8518 (speakers, microphones, amplifiers), 8471 (computers and related equipment), and 8544 (wiring and cables). For automotive and manufacturing importers, wiring harnesses under 8544.30 and electrical automotive components are high-volume subheadings.
The classification challenge in Chapter 85 is the precision required to describe product function. A product's principal function — not its appearance or marketing description — determines the heading. A power bank that is principally a lithium-ion battery classifies under 8507. A power bank with a significant built-in radio or Bluetooth speaker may classify elsewhere. Technical product descriptions are essential for accurate classification. For nearshoring-related electronics, see our Mexico and USMCA industry page.
Common HTS Codes in Chapter 85
| HTS Code | Description | Representative Duty Rate |
|---|---|---|
| 8471.30 | Portable automatic data processing machines (laptops) | Free |
| 8504.40 | Static converters (power supplies, chargers) | 1.5% – 3% |
| 8507.60 | Lithium-ion accumulators (batteries) | 3.4% |
| 8517.62 | Machines for reception/conversion/transmission of data (routers, switches) | Free |
| 8518.21 | Single loudspeakers mounted in enclosures | 4.9% |
| 8518.40 | Audio-frequency electric amplifiers | 4.9% |
| 8523.51 | Solid-state non-volatile storage devices (USB drives, SSDs) | Free |
| 8528.72 | Color television receivers/monitors | 3.9% |
| 8541.40 | Light-emitting diodes (LEDs) | Free |
| 8544.30 | Ignition wiring sets and other wiring sets for vehicles | 5% |
Note: Many Chapter 85 products benefit from the WTO Information Technology Agreement (ITA), which sets duty at zero for qualifying IT products. Computers, networking equipment, semiconductors, and storage devices are among the beneficiaries. However, not all electronics qualify — batteries, speakers, and certain consumer devices fall outside the ITA scope and face standard MFN rates.
Duty Rates & Additional Tariffs
Base MFN duty rates in Chapter 85 are generally low compared to chapters like apparel or footwear. Many products enter duty-free under the ITA. Non-ITA products typically face rates of 1.5% to 5%. However, the base rate is almost never the full story for electronics importers.
Section 301 tariffs: This is the dominant cost factor for electronics importers sourcing from China. Section 301 tariffs of 25% apply to a wide range of Chapter 85 products, including batteries, power supplies, speakers, and wiring. A lithium-ion battery pack with a 3.4% base rate faces a combined rate of 28.4% from China. The same product from South Korea, Japan, or Vietnam faces only 3.4%. For current Section 301 coverage, see our Section 301 tariff guide.
Section 232 tariffs: Certain electrical steel and related components may be subject to Section 232 tariffs on steel and aluminum products. This primarily affects industrial electrical equipment rather than consumer electronics.
AD/CVD exposure: Specific products like certain crystalline silicon photovoltaic cells and modules from China face antidumping and countervailing duties that can be substantial.
PGA & Compliance Requirements
FCC (Federal Communications Commission)
Electronic devices that emit radio frequency energy must comply with FCC regulations. This includes virtually all devices with a processor, wireless capability, or digital circuitry. Products may require FCC certification, declaration of conformity, or verification depending on the device type. FCC compliance must be established before the product enters the United States.
CPSC (Consumer Product Safety Commission)
Consumer electronics, particularly battery-powered devices, are subject to CPSC general product safety requirements. Products designed for children must meet additional testing and certification requirements. CPSC has issued specific guidance on lithium battery safety in consumer products. Recalls of non-compliant electronics are common and costly.
Hazmat / DOT (Lithium Batteries)
Lithium and lithium-ion batteries are classified as hazardous materials for transport purposes under DOT and IATA regulations. Shipping batteries internationally requires specific packaging, labeling, and documentation. Battery watt-hour ratings determine the applicable hazmat class and transport restrictions. Importers must coordinate hazmat compliance with their freight forwarders and ensure proper documentation accompanies each shipment.
EPA (Energy Star and Efficiency Standards)
Certain electronic products are subject to DOE energy efficiency standards. Products making Energy Star claims must be certified through the EPA Energy Star program. Non-compliant products may face enforcement action and removal from the market.
Country of Origin Considerations
For electronics, country of origin is primarily a Section 301 cost question. The base duty rates are so low that origin would be a minor factor in a world without additional tariffs. Section 301 changes that equation fundamentally.
China: China remains the world's dominant electronics manufacturer. Section 301 tariffs of 25% on most Chapter 85 products have increased landed costs significantly. Some importers have absorbed the cost. Others have restructured supply chains to perform final assembly in countries not subject to Section 301 tariffs. CBP actively scrutinizes claims that products assembled from Chinese components in third countries have genuinely undergone substantial transformation.
South Korea, Japan, Taiwan: Major electronics manufacturing centers that avoid Section 301 tariffs. Products manufactured in these countries face only the base MFN rate, which is often zero or low single digits. For high-value electronics, the Section 301 savings from non-China sourcing can be substantial.
USMCA (Mexico): Electronics manufacturing in Mexico is growing, particularly for automotive electronics and wiring harnesses. USMCA-qualifying products can enter duty-free. The rules of origin require careful analysis, especially for products with components sourced from multiple countries. For nearshoring analysis, see our nearshoring Mexico checklist.
Common Classification Mistakes
Classifying by Marketing Name Instead of Function
Electronics are classified by their principal function, not their marketing name. A "smart speaker" that primarily plays music classifies as a loudspeaker (8518), not a computer. A "portable charger" that is principally a battery classifies under 8507, not 8504. Importers who use product marketing language instead of technical functional descriptions on their customs entries frequently trigger reclassification.
Treating Multi-Function Devices as a Single Product
Many modern electronics combine multiple functions (e.g., a device that is a speaker, a battery charger, and a Bluetooth receiver). The classification depends on which function provides the "essential character" of the product. If no single function dominates, the product classifies under the heading that occurs last in the HTS. This requires careful analysis of the product's design, marketing, and use.
Ignoring Watt-Hour Ratings for Battery Classification
Lithium-ion batteries are classified based on their characteristics, and the watt-hour rating affects both the HTS classification and the hazmat transport requirements. Importers who do not obtain and verify watt-hour ratings for their battery products face both classification errors and potential transport violations.