LEDVANCE LLC – Addendum to Filament Exclusion Request

LEDVANCE LLC, makers of SYLVANIA branded light bulbs (lamps), imports a component (filament) that is 

used in a finished incandescent, halogen and fluorescent lamps. The filament is made of tungsten wire which 

is wound at least one time in a spiral. There are variations of the filament design (wire diameter, length of 

wire and number of turns) which are dependent on the power rating of the finished lamp.

SYLVANIA light bulbs have been a household name in America since 1901. Our US headquarters is in 

Massachusetts, and we employ more than a thousand US workers nationwide, over 650 of whom are in our 

manufacturing plants and distribution centers. Our factories in St. Marys, Pennsylvania and Versailles, 

Kentucky – both rural areas -- carry on our long tradition of producing high-quality light bulbs, using 

components from both the US and abroad. In many cases, our US workers represent multiple generations of 

local families. 

A. Description of lamp types

a. Incandescent

Base

Filament

Bulb

Leadwire
b. Halogen

c. Fluorescent
B. Filament

An incandescent and halogen lamp (diagrams a & b) consists of a wire filament attached to a mount

(leadwires) enclosed in a glass bulb. When the lamp is connected to an electrical circuit, the electric 

current passing through the filament wire must overcome its resistance and the power consumed heats 

the filament to incandescence (causes it to glow). The consumed power can range from 4 – 1500 watts 

with color temperatures from 2300 – 4000 Kelvin.

The filament in a fluorescent lamp (diagram c) works slightly differently than in an incandescent lamp. It is 

also attached to a mount (leadwires) enclosed in a glass bulb but this filament is coated with a material 

that will emit electrons when it is heated. When current passes through the filament it does not 

incandesce but becomes just a heater. All fluorescent lamps require a ballast to provide high starting 

voltage and to regulate the current during operation.

a. Physical Properties

i. Material – Tungsten wire (symbol W)

ii. Overall Diameter: 0.15 – 3.0mm

iii. Overall Length: 10.0 – 50.0mm

iv. Coil Weight: 4.0 – 75.0mg

b. Geometry

i. Single coil – incandescent & halogen lamps

ii. Coil coil – incandescent and halogen lamps

iii. Stick coil – fluorescent lamps
c. Various Forms

C. US or Third Country Options

Filaments are currently made primarily by Chinese suppliers. However, we will be shifting to a 

supplier based outside China, discontinuing use of Chinese suppliers.

D. Draft CBP Language

Filament coils for incandescent, halogen and fluorescent lamps made of Tungsten wire (symbol W) 

with an overall diameter of 0.15 – 3.0mm, overall length of 10.0 – 50.0mm, and coil weight of 4.0 –

75.0mg.

E. Confidentiality Statement

Consistent with USTR's Section 301 notice, LEDVANCE LLC requests confidential treatment for the

information designated as business confidential in this submission, Such information consists of 

information that would not customarily be released to the public, including business or trade secrets 

regarding production costs and processes, data on sales, product characteristics, customers, 

destinations, and other product, sales, and cost-related business secrets. Business confidential 

information has been indicated herein by enclosing it in single brackets. A public version of these 

comments is also being filed with all confidential information removed.