CCSB DOCKET 2011-3
SECTION I
SUBJECT 8
Re: String Lights or Rope Lights, including Christmas or holiday lights
Staff Contact: William F. Mascaro
Nathan D. Ripke
Telephone — (703) 838-1834
Telephone — (703) 838-1869
mascaro@nmfta.org
ripke@nmfta.org
Proponent: Commodity Classification Standards Board
Present Classification Provisions
Item
Description
Class
LAMPS OR LIGHTING GROUP: subject to item 109000
Lamps or Lighting Fixtures, see Notes, items 109701, 109702, 109703
and 109704, 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 109705;
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 109706:
Sub 1
Less than 1 ............................................................................................. 400
Sub 2
1 but less than 2 .................................................................................... 300
Sub 3
2 but less than 4 .................................................................................... 250
Sub 4
4 but less than 6 .................................................................................... 150
Sub 5
6 but less than 8 .................................................................................... 125
Sub 6
8 but less than 10 .................................................................................. 100
Sub 7
10 but less than 12 .................................................................................. 92.5
Sub 8
12 but less than 15 .................................................................................. 85
Sub 9
15 but less than 22.5 ............................................................................... 70
Sub 10
22.5 but less than 30 ............................................................................... 65
Sub 11
30 or greater ............................................................................................ 60
109701
NOTE—Not Involved.
109702
NOTE—Not Involved.
109703
NOTE—Not Involved.
109704
NOTE—Not Involved.
109705
NOTE—Not Involved.
109706
NOTE—Not Involved.
109886
Sets or Outfits, Christmas tree lighting, consisting of wiring, plugs, sockets
and equipment of incandescent lamps (bulbs), in boxes ................... 100
109700
©2011 National Motor Freight Traffic Association, Inc.
Subject 8, Page 1 of 5
CCSB DOCKET 2011-3
SECTION I
SUBJECT 8
Proposed Classification Provisions
Item
109700
109701
109702
109703
109704
109705
109706
109886
Description
Class
LAMPS OR LIGHTING GROUP: subject to item 109000
Lamps or Lighting Fixtures, see Notes, items 109701, 109702, 109703
and 109704, 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 109700
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 109886. 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 109700.
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 Study1.
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.
1
Subject 8, Page 2 of 5
©2011 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2011-3
SECTION I
SUBJECT 8
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, 1982.
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.
LED rope lights on a reel.
A strand of string lights
shipped with removable
protective bulb covers.
One example of a strand
of decorative string lights.
©2011 National Motor Freight Traffic Association, Inc.
Subject 8, Page 3 of 5
CCSB DOCKET 2011-3
SECTION I
SUBJECT 8
Transportation Characteristics
Density: Data on the current record totals 586 figures revealing a range in density from
1.06 to 38.98 pcf, with a simple average density of 6.44 pcf. See the frequency distribution
below:
Frequency Distribution
34%
% of Figures in Interval
35%
30%
23%
25%
20%
20%
15%
7%
10%
5%
3%
5%
4%
3%
1%
0%
1%
0%
Less
than 1
1 but
less
than 2
2 but
less
than 4
4 but
less
than 6
6 but
8 but 10 but 12 but 15 but 22.5 but 30 or
less
less
less
less
less
less
greater
than 8 than 10 than 12 than 15 than than 30
22.5
Density Intervals (pcf)
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 less 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 5
©2011 National Motor Freight Traffic Association, Inc.
CCSB DOCKET 2011-3
SECTION I
SUBJECT 8
Relationship to CCSB Policies and Guidelines
Information of record indicates that the involved commodities range in density from
1.06 to 38.98 pcf and exhibit no unusual or significant handling, stowability or liability
considerations. Currently, Christmas tree lighting sets or outfits meeting the description of item
109886 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
109700.
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 109886 and concurrently amending item 109700 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.
©2011 National Motor Freight Traffic Association, Inc.
Subject 8, Page 5 of 5