HS Code | Official Doc | Tariff Rate | Origin | Destination | Effective Date |
---|---|---|---|---|---|
9609202000 | Doc | 37.5% | CN | US | 2025-05-12 |
3901909000 | Doc | 61.5% | CN | US | 2025-05-12 |
Okay, let's break down the classification and tax implications for your declared goods, "PENCIL REFILL," based on the provided HS codes. I'll present this in a structured format for clarity.
Analysis of Declared Goods: PENCIL REFILL
You have two HS codes associated with your declaration, which suggests your "PENCIL REFILL" might be categorized in different ways depending on its composition and specific characteristics. Here's a detailed look at each:
1. HS Code: 9609.20.20.00 – Pencil Leads (Black or Colored, Not Over 1.5mm)
- Heading 9609: This broadly covers pencils, crayons, pastels, drawing charcoals, writing or drawing chalks, and tailor's chalks.
- 9609.20: Specifically refers to pencil leads.
- 9609.20.20: This narrows it down to black or colored pencil leads not exceeding 1.5mm in maximum cross-sectional dimension.
- 9609.20.20.00: The final digits indicate a specific tariff classification within that category.
Tax Implications:
- Basic Duty: 0.0%
- Additional Tariff: 7.5% (This is an extra tax on top of the basic duty.)
- Post April 2, 2025 Additional Tariff: 30% (Be aware that the additional tariff will increase significantly after this date.)
- Total Tax: 37.5%
Important Considerations:
- Dimensions: Crucially, this HS code applies only if your pencil leads are 1.5mm or smaller in diameter. If they are larger, a different HS code will be required.
- Material: The material composition of the lead (e.g., graphite, wax-based) doesn't affect this specific HS code, but it could be relevant if the leads contain unusual materials.
- Color: The code covers both black and colored leads.
2. HS Code: 3901.90.90.00 – Polymers of Ethylene (Other)
- Heading 3901: This covers polymers of ethylene in primary forms (e.g., pellets, granules, powders). This suggests your pencil refill may be made of polyethylene plastic.
- 3901.90: This specifies "other" polymers of ethylene.
- 3901.90.90: Further defines this as "other" within the "other" category.
- 3901.90.90.00: The final digits represent a specific tariff classification.
Tax Implications:
- Basic Duty: 6.5%
- Additional Tariff: 25.0%
- Post April 2, 2025 Additional Tariff: 30%
- Total Tax: 61.5%
Important Considerations:
- Material Composition: This HS code is appropriate only if the primary component of your pencil refill is polyethylene. If other plastics or materials are used, a different HS code will be needed.
- Form: The polyethylene should be in primary forms (pellets, granules, powders). If it's already processed into a finished shape, this code may not be correct.
- Additives: The presence of additives (e.g., pigments, stabilizers) could affect the HS code, depending on their nature and quantity.
Recommendations & Next Steps
- Confirm Material Composition: Precisely determine the materials used in your pencil refills. This is the most important step. If it's solely polyethylene, 3901.90.90.00 is likely correct. If it's graphite/wax-based, 9609.20.20.00 is more appropriate. If it's a combination, you may need to consult a customs expert.
- Verify Dimensions: If you are using 9609.20.20.00, accurately measure the diameter of your pencil leads to ensure they are 1.5mm or smaller.
- Check for Additives: If using 3901.90.90.00, list all additives and their percentages.
- Consider Certification: Depending on the intended use of the pencil refills (e.g., for children), you may need to provide safety certifications (e.g., EN71, ASTM D4236).
- Single vs. Multiple HS Codes: If your pencil refill consists of multiple components (e.g., a plastic casing and a graphite lead), you may need to declare each component under a separate HS code.
- Consult a Customs Broker: For complex cases or if you are unsure about the correct HS code, it is highly recommended to consult a licensed customs broker or a customs expert in China. They can provide accurate guidance and ensure compliance with all relevant regulations.
Disclaimer: I am an AI assistant and cannot provide definitive customs advice. This information is for general guidance only. Always consult with a qualified customs professional for specific advice related to your situation.