Staff Contact: William F. Mascaro Telephone (703) Nathan D. Ripke Telephone (703)

Transcription

1 Re: String Lights or Rope Lights, including Christmas or holiday lights Staff Contact: William F. Mascaro Telephone (703) Nathan D. Ripke Telephone (703) Proponent: Commodity Classification Standards Board Present Classification Provisions Item Description Class LAMPS OR LIGHTING GROUP: subject to item Lamps or Lighting Fixtures, see Notes, items , , and , viz.: Floor Standing Lamps, with or without integral tray, also in Package 817; Fluorescent or High Intensity Discharge (HID) Lighting Fixtures, NOI, with equipment of transformer or ballast, also in Packages 220, 233, 790, 919, 1406, 2228, 2312, 2477 or E2533, see Note, item ; Housings, recessed incandescent lighting fixture; Lamps, NOI, also in Packages 794, 817, 1424, 1467, 2204 or 5F; Lighting Fixtures, NOI; Parts, lamp, lantern or lighting fixture, NOI; In boxes or crates, subject to Items 170 and 171 and having a density in pounds per cubic foot of, see Note, item : Sub 1 Less than Sub 2 1 but than Sub 3 2 but than Sub 4 4 but than Sub 5 6 but than Sub 6 8 but than Sub 7 10 but than Sub 8 12 but than Sub 9 15 but than Sub but than Sub or greater NOTE Not Involved NOTE Not Involved NOTE Not Involved NOTE Not Involved NOTE Not Involved NOTE Not Involved Sets or Outfits, Christmas tree lighting, consisting of wiring, plugs, sockets and equipment of incandescent lamps (bulbs), in boxes National Motor Freight Traffic Association, Inc. Subject 8, Page 1 of 5

2 Proposed Classification Provisions Item Description Class LAMPS OR LIGHTING GROUP: subject to item Lamps or Lighting Fixtures, see Notes, items , , and , viz.: String Lights or Rope Lights; [Other Articles Listed No Change.] [Remainder of Item No Change.] NOTE No Change NOTE No Change NOTE No Change NOTE No Change NOTE No Change NOTE No Change Sets or Outfits, Christmas tree lighting, etc.... Cancel; see item Analysis This proposal is based on information developed through Research Project 1123, which was initiated by the CCSB in December, 2010 in response to interpretive questions on lighting sets equipped with LED bulbs instead of incandescent bulbs. When equipped with incandescent bulbs and represented as Christmas tree light strands, the product is classified under item However, when equipped with LED bulbs, or when represented as decorative or ornamental string lighting other than for use on Christmas trees, the product is classified under item During the course of Research Project 1123, 72 shippers or manufacturers of string lights or rope lights and 14 associations believed to represent those manufacturers and shippers were contacted in December of 2010 and February of 2011 and invited to participate in the research. From those mailings, four shippers provided usable information, one shipper stated that they do not move these commodities via LTL, and five companies stated that they do not ship or manufacture string lights or rope lights. None of the associations provided useable information, however five responded that they do not represent shippers or manufacturers of string lights or rope lights, while one association refused to accept a second mailing attempt. Additional information was developed through carrier-submitted Shipment Information Forms, CCSB dock surveys and the CCSB s Density Study 1. 1 The Density Study is part of an ongoing effort by the CCSB to collect information on actual shipments; it is not tied to any particular research project, nor does it target any particular product category. Carriers that choose to participate in the study periodically submit shipment data captured through their respective freight auditing programs. The data is identified by NMFC item, and only verifiable data points, which include the weight and the dimensions and/or cube of the shipping unit involved, are used. Subject 8, Page 2 of National Motor Freight Traffic Association, Inc.

3 The provisions for Christmas tree lighting sets or outfits were adopted from the rails in 1936 and remained substantially unchanged until action was taken on Subject 4 of Docket 816 (September, 1981). That proposal was for clarification purposes, including adding the noun Sets to the description and moving the provisions from the Electrical Equipment Group to the Lamps or Lighting Group. The changes were first published in Supplement 1 to NMF 100-I, effective May 8, Although the provisions for Christmas tree lighting sets and outfits have remained essentially unchanged since the inception of the NMFC, the nature and use of these products have evolved beyond just Christmas tree lighting to include a variety of applications. The original provisions for Christmas tree lights describing wire sets or outfits consisting of incandescent bulbs are just one of the various types manufactured and represented as string lights and rope lights moving via LTL service today. String lights and rope lights now include those with miniature incandescent bulbs, icicle-styled strands and strands with decorative or protective bulb covers of all shapes and sizes. Technological advances have also resulted in manufacturers producing a variety of LED ropes and strands that are shipped on reels in boxes or in inner containers in boxes. These ropes or strands may be equipped with color shades and/or diffusers which can affect product density. Examples of the involved lights are shown below. C7 and C9 (size) incandescent bulbs were the original style of string lights. Today bulbs may be LED or incandescent. Miniature string lights may consist of LED or incandescent bulbs. A strand of string lights shipped with removable protective bulb covers. LED rope lights on a reel. One example of a strand of decorative string lights National Motor Freight Traffic Association, Inc. Subject 8, Page 3 of 5

4 % of Figures in Interval CCSB DOCKET Transportation Characteristics Density: Data on the current record totals 586 figures revealing a range in density from 1.06 to pcf, with a simple average density of 6.44 pcf. See the frequency distribution below: 35% 30% 25% 20% 23% Frequency Distribution 34% 20% 15% 10% 5% 0% 0% Less than 1 3% 1 but than 2 2 but than 4 4 but than 6 6 but than 8 7% 8 but than 10 5% 10 but than 12 Density Intervals (pcf) 4% 3% 12 but than but than % 1% 22.5 but than or greater As depicted in the graph, the observations are distributed throughout the density range with no clear breaks or gaps, although 77 percent of the observations of record have densities of 2 but than 8 pcf. Handling: These products are tendered for shipment on reels in boxes or in inner containers in boxes. String lights or rope lights that are on reels are generally denser and larger in quantity. Handling would be comparable to other like-packaged freight. Stowability: Although there is no indication of any unusual or significant stowing considerations, heavy freight should not be loaded on top of the lights to avoid damage, especially to the bulbs. Liability: Holiday lights can be time-perishable, but there is no indication on this record that this has been an issue. String lights and rope lights are not prone to spontaneous combustion or explosion. Information of record provided by shippers representing up to 36% of the market for this commodity reveals zero freight claims in the past year, indicating that these products are not unusually susceptible to theft or damage. A limited amount of information on the value indicates values per pound ranging from $1.60 to $44.12, with a simple average of $13.46 per pound. Subject 8, Page 4 of National Motor Freight Traffic Association, Inc.

5 Relationship to CCSB Policies and Guidelines Information of record indicates that the involved commodities range in density from 1.06 to pcf and exhibit no unusual or significant handling, stowability or liability considerations. Currently, Christmas tree lighting sets or outfits meeting the description of item are assigned class 100, while nonconforming Christmas tree lighting sets or outfits, and all other string lights or rope lights, are classified under the density-based provisions of item CCSB policy provides that commodities or commodity groups exhibiting a wide density range not accurately reflected by a single overall average density may be assigned densitybased classes; especially when there are no unusual or significant stowing, handling or liability characteristics and where there is no other feasible means of effectively narrowing the range. And where densities are distributed throughout the range, commodities or commodity groups may be assigned classes predicated on a full density scale. Cancelling item and concurrently amending item to specifically name String Lights or Rope Lights, as proposed, would address interpretive questions and reflect the commodities transportation characteristics, in keeping with CCSB policies National Motor Freight Traffic Association, Inc. Subject 8, Page 5 of 5