4107197040
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Product Description
HS Code 4107.19.70.40 refers to tanned or crust (partially processed) hides of bovine (including buffalo) or equine (horse) origin that have undergone further processing but remain hair-on or hairless (as specified, hairless in this context), non-patterned, and sold as full hides (i.e., unsplit and whole-pelt). The defining characteristic of this classification is its exclusive end-use: it is specifically designated for the manufacture of gloves and garments (e.g., leather jackets, coats, skirts, and other apparel items).
This distinguishes it from other subcategories under the same broader HS heading (4107.19):
- 4107.19.70.10: Intended for industrial applications such as transmission belts, drive belts, and similar mechanical components.
- 4107.19.70.20: Allocated for crafting bags, suitcases, luggage cases, straps, collars, harnesses, and similar leather accessories.
- 4107.19.70.90: Reserved for miscellaneous or unspecified leather products not falling under the above categories.
The raw material must meet international standards for tanning (chrome, vegetable, or synthetic) or crust processing, with no decorative embossing or artificial patterning. The hides are typically graded for softness, flexibility, and durability—key attributes for garment and glove production.
Applicable Tariff Rates
Tariff rates vary by country of importation and trade agreement status. Below are representative examples for major economies (rates apply to ad valorem duties unless otherwise noted):
| Country/Region | Base MFN Duty Rate | FTAs / Preferential Rates (if applicable) | Notes |
|---|---|---|---|
| United States | 3.6% (Section XI, Chapter 41) | 0% under USMCA (if originating from Canada/Mexico) | Subject to possible anti-dumping measures if from specific countries (e.g., China); verify via CBP rulings. |
| European Union | 4.5% (Integrated Tariff TARIC) | 0% under EU-GCC or EU-Korea FTA (if compliant) | May be subject to anti-dumping duties (e.g., on leather from Vietnam or China); check latest EU Commission regulations. |
| China | 6.5% (Customs Tariff 2024) | 0% under RCEP (for qualifying ASEAN+3 origin) | Requires Certificate of Origin for preference claims. |
| India | 15% (Basic Customs Duty) + 10% Social Surcharge + 5% Safeguard Duty (temporary) | 0% under SAFTA (for SAARC nations) | High protective duty; recent safeguard measures apply to leather from certain ASEAN countries. |
| Japan | 4.0% | 0% under Japan-Vietnam EPA, Japan-EU EPA | Strict phytosanitary and leather treatment documentation required. |
⚠️ Important: Final duty rates depend on the country of origin, preferential trade agreements in force, and any temporary safeguard or countervailing duties. Importers must consult national customs databases (e.g., US CBP, EU TARIC, China Customs) and consider using binding tariff information (BTI) rulings for certainty.
Duty Breakdown Example (for a $10,000 shipment to the U.S.)
Assuming MFN rate (3.6%) and no applicable FTA:
| Component | Calculation | Amount (USD) |
|---|---|---|
| CIF Value (Cost, Insurance, Freight) | — | $10,000 |
| Ad Valorem Duty (3.6%) | $10,000 × 0.036 | $360 |
| Merchandise Processing Fee (MPF) | 0.3464% of value (min $27.23, max $538.04) | $34.64 |
| Harbor Maintenance Fee (HMF) | 0.125% of value | $12.50 |
| Total Landed Duty & Fees | — | $407.14 |
Note: Additional fees may apply, e.g., FDA (if applicable), bonded warehouse charges, or anti-dumping duties if triggered.
Trade Regulations & Compliance Requirements
1. Harmonized System (HS) Classification Rules
- Governed by the World Customs Organization (WCO) and national adaptations (e.g., U.S. HTSUS, EU TARIC).
- Classification hinges on:
- Animal origin (bovine/equine),
- Tanning status (tanned/crust),
- Hair presence (hairless in this case),
- Surface finish (non-patterned),
- Primary use (garment/glove vs. other).
- Misclassification (e.g., declaring for garments but used for belts) can result in penalties, seizure, or retrospective duty adjustments.
2. Origin Certification & Preferential Treatment
- To claim FTA benefits (e.g., 0% duty under RCEP), exporters must provide:
- Certificate of Origin (COO) compliant with the specific agreement.
- Direct consignment rule adherence (goods must not undergo further processing or re-export en route).
- Documentation must be submitted at time of entry (e.g., using Form E for ASEAN, Form AK for ASEAN-China).
3. Environmental & Labor Compliance
- REACH (EU): Limits on heavy metals (chromium VI ≤ 3 ppm), azo dyes, and organic solvents in leather.
- TSCA (U.S.): Restrictions on hazardous chemicals used in tanning.
- ILO Conventions: No forced labor; proof of ethical sourcing increasingly required by U.S. (UFLPA) and EU (EUDR) regulations.
- CITES: Not applicable (bovine/equine hides not endangered), but if from protected wildlife hybrids, additional permits needed.
4. Labeling & Marking
- Must indicate:
- Country of origin (e.g., "Made in Vietnam"),
- Fiber/content (100% bovine leather),
- Tanning method (optional but recommended for transparency).
- Non-compliance risks rejection at port (e.g., under U.S. Tariff Act § 1304).
5. Special Measures
- Anti-Dumping Duties (ADD): Imposed on leather from China (e.g., rates up to 28.7% for garment-grade hides).
- Safeguard Duties: Temporarily applied by India, Turkey, etc., to protect domestic leather industries.
- Sanitary/Phytosanitary (SPS): While leather is processed, some countries require proof of chemical treatment to prevent pathogen transfer.
Strategic Recommendations for Importers
✅ Pre-shipment: Obtain Binding Tariff Information (BTI) from your national customs authority.
✅ Sourcing: Prioritize suppliers with ISO 17025-certified tanning facilities and REACH/TSCA compliance reports.
✅ Documentation: Maintain a full audit trail (tanning records, COO, commercial invoice, packing list).
✅ Risk Mitigation: Use trade compliance software to monitor real-time duty changes and regulatory updates.
This classification (4107.19.70.40) is highly specialized—accurate declaration is critical to avoid costly customs delays, audits, or fines. Always verify with a licensed customs broker or trade attorney for jurisdiction-specific guidance.