Not necessarily. LED luminaires and traditional fluorescent or incandescent fixtures can be classified under different HTS headings depending on their design and light source technology. The shift to LED has created classification ambiguity for hybrid or retrofit products, and importers should verify the correct heading — and any applicable Section 301 exposure — with a licensed customs broker.

Many lighting products are subject to DOE energy-efficiency standards under the Energy Policy and Conservation Act. Importers must ensure covered products meet applicable efficacy and wattage requirements and, for certain categories, file a DOE Compliance Certification before or at the time of importation.