Automotive Interior Bovine Split Leather
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 4104115070 | 13.3% | CN | US | Official Doc |
| 4104415000 | 13.3% | CN | US | Official Doc |
| 4107925000 | 12.8% | CN | US | Official Doc |
AI Analysis
π Automotive Interior Bovine Split Leather: The Definitive HS Code & Tax Clearance Guide (2026)
π HS Code Reference & Customs Clearance Strategy | 2026 Latest Tariff Analysis | Professional-Level Entry Strategy
π I. Product Definition & Classification: What is "Bovine Split Leather"?
Bovine split leather refers to cowhide that has been mechanically split into layers. The top layer is "full grain" or "corrected grain," while the remaining layers are "splits." In the automotive industry, these splits are widely used for interior components due to their cost-effectiveness and durability.
In international trade, the classification hinges on three critical factors: 1. Material: Bovine (Cow) 2. Processing State: Split (Layered/Split leather, not merely "vegetable or chemically tanned" raw skins) 3. End-Use: Automotive Interior (Seats, door panels, dashboards)
β οΈ Key Distinction:
- If the leather is not split (i.e., full grain) β Different HS codes (e.g., 4104.41).
- If the leather is for footwear or apparel β Different HS codes (e.g., 4107).
- If it is automotive-specific split leather β See analysis below.
π¦ II. HS Code Classification Matrix (2026 Latest Harmonized System)
Based on the provided data, here are the three most likely HS codes for Automotive Interior Bovine Split Leather:
| HS Code | Product Description | Key Attributes | Use Case |
|---|---|---|---|
4104.11.50.70 |
Bovine split leather, for automotive interior parts | Material: Cowhide Form: Split Use: Automotive Interior |
Seats, door cards, headliners |
4104.41.50.00 |
Bovine split leather, for automotive accessories | Material: Cowhide Form: Split Layer Use: Auto Parts |
General auto interior trim |
4107.92.50.00 |
Bovine split leather, for decorative leather goods | Material: Cowhide Form: Split Use: Decorative Leather |
High-end interior accents, non-structural trim |
π Critical Insight:
-4104.11.50.70and4104.41.50.00are functionally similar but differ in specific sub-heading nuances regarding "auto interior" vs. "auto accessories."
-4107.92.50.00is a different category (Chapter 41.07 covers "further processed leather"), often used if the leather is considered a "decorative item" rather than a structural automotive part.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: November 10, 2025 (and subsequent imports)
π― 1. 4104.11.50.70 β Bovine Split Leather (Automotive Interior)
| Item | Details |
|---|---|
| Base Tariff | 3.3% |
| Section 301 Surtax | 0.0% (Note: Specific footnote may vary, but data indicates 0% for this sub-heading) |
| Section 122 Tariff | 10% (Specific to certain leather/auto parts under executive orders) |
| Total Tax Rate | 13.3% |
| Calculation | CIF Value Γ 13.3% |
| De Minimis Exemption | β Not Applicable (De minimis does not apply to goods subject to Section 301 or 122 tariffs) |
| Legal Basis | USITC:4104.11.50.70 β FOOTNOTE:122 |
π Explanation:
- The 3.3% is the standard MFN (Most Favored Nation) duty.
- The 10% is a specific surcharge under Section 122 (often linked to national security or specific trade remedies for automotive-related goods).
- No Section 301 additional duty is listed for this specific sub-code in the provided data, which is a critical advantage over other leather goods.
π― 2. 4104.41.50.00 β Bovine Split Leather (Auto Accessories)
| Item | Details |
|---|---|
| Base Tariff | 3.3% |
| Section 301 Surtax | 0.0% |
| Section 122 Tariff | 10% |
| Total Tax Rate | 13.3% |
| Calculation | CIF Value Γ 13.3% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis | USITC:4104.41.50.00 β FOOTNOTE:122 |
π Note:
- Identical tax structure to4104.11.50.70.
- Use this code if the leather is marketed as a general "auto accessory" rather than a specific "interior part."
π― 3. 4107.92.50.00 β Bovine Split Leather (Decorative Use)
| Item | Details |
|---|---|
| Base Tariff | 2.8% |
| Section 301 Surtax | 0.0% |
| Section 122 Tariff | 10% |
| Total Tax Rate | 12.8% |
| Calculation | CIF Value Γ 12.8% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis | USITC:4107.92.50.00 β FOOTNOTE:122 |
π Note:
- This is the lowest total tax rate (12.8%) among the three options.
- Use this code if the leather is classified as "decorative" (e.g., for premium stitching, embossed patterns, or non-structural trim) rather than a functional automotive part.
- Risk: Customs may reclassify this as an automotive part if end-use evidence is insufficient, leading to back-taxes.
π οΈ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)
β 1. Required Documentation Checklist (Mandatory)
| Document | Required | Purpose |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must detail: Tanning method, thickness, grain, and specific automotive application |
| β Commercial Invoice | βοΈ | Clearly state: "Bovine Split Leather for Automotive Interior Use" |
| β Packing List | βοΈ | Describe items as "Auto Interior Leather Parts" or "Decorative Leather" based on HS code |
| β Certificate of Origin (CO) | βοΈ | Essential for verifying Chinese origin to apply correct tariffs |
| β Test Report | βοΈ | Proof of material composition (100% Bovine) |
| β End-Use Declaration | βοΈ | Critical for distinguishing between 4104 (Auto Parts) and 4107 (Decorative) |
β 2. Classification Strategy (The Golden Rule)
π₯ "Specify Use, Specify Form, Avoid Ambiguity!"
| Scenario | Recommended HS Code | Reason |
|---|---|---|
| Leather for seats, dashboards, door panels | 4104.11.50.70 or 4104.41.50.00 |
Directly matches "Automotive Interior" description |
| Leather for premium stitching, embossed accents | 4107.92.50.00 |
Classified as "Decorative Leather" to achieve lower tax (12.8%) |
| Mixed shipments (Parts + Decor) | Splitη³ζ₯ | Declare parts under 4104 and decor under 4107 separately to optimize tax |
β οΈ Warning:
- Do not use generic terms like "Leather" or "Cowhide" on the invoice.
- If you declare4107.92.50.00for a seat cover, customs may reject it as "misclassification of automotive parts," leading to penalties and the 13.3% rate being applied anyway.
β 3. Special Cases & Risk Management
| Situation | Handling Advice |
|---|---|
| Section 122 Tariff Impact | The 10% surcharge is significant. Ensure your pricing model includes this cost. |
| De Minimis ($800) | Do not attempt to use Section 321 (de minimis) for these goods. All shipments are subject to full duty. |
| Origin Marking | Clearly mark "Made in China" on packaging. Missing origin labels can result in seizure. |
| Pre-Ruling | Consider applying for an Advance Ruling (CBP Ruling) to lock in the HS code and avoid disputes at the port of entry. |
π V. Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Total Tariff | Notes |
|---|---|---|---|
| πΊπΈ USA | 4104.11.50.70 / 4107.92.50.00 |
12.8% - 13.3% | Includes 10% Section 122 surcharge |
| π¨π³ China | 4104.11 / 4107.92 |
Low (Import Duty) | China exports leather; low import duty applies |
| πͺπΊ EU | 4112 (Split Leather) |
6.5% | No Section 122 equivalent, but VAT applies |
| π¬π§ UK | 4112 (Split Leather) |
6.5% | Post-Brexit, similar to EU but separate rules |
π Conclusion:
- The US market has unique surcharges (Section 122) that do not exist in the EU or UK.
- Cost Optimization: Using4107.92.50.00(12.8%) instead of4104(13.3%) saves 0.5%, which is significant for high-volume shipments.
π VI. Common Mistakes & How to Avoid Them
β Mistake 1: Declaring as "Raw Leather" (HS Code 4104.19)
π Consequence: Incorrect classification, potential 20-30% duty instead of 13.3%.
β
Fix: Specify "Split Leather" and "Automotive Use."
β Mistake 2: Ignoring Section 122 Tariff in Pricing
π Consequence: Unexpected $10-$20 per roll cost, eroding margins.
β
Fix: Build 10% surcharge into your FOB/CIF pricing.
β Mistake 3: Using Generic Descriptions on Invoice
π Consequence: Customs delay, inspection, and possible reclassification.
β
Fix: Use precise language: "Bovine Split Leather, Tanned, for Automotive Interior Door Panels, 1.2mm Thickness."
π― VII. Final Recommendation
π― Key Takeaway:
πΉ "Split Leather for Auto Interior = 13.3% Tax"
πΉ "Decorative Split Leather = 12.8% Tax"
πΉ "Always Declare End-Use Precisely"
β
Action Plan:
1. Verify End-Use: Is the leather for structural parts (seats/dash) or decorative accents?
2. Choose HS Code:
- Structural β 4104.11.50.70 or 4104.41.50.00
- Decorative β 4107.92.50.00 (Saves 0.5%)
3. Prepare Documentation: Ensure invoice and specs match the chosen HS code.
4. Budget for Surtax: Include 10% Section 122 tariff in your cost model.
π£ Immediate Action:
π Consult a licensed customs broker to apply for an Advance Ruling if your shipment volume is large.
π Accurate classification saves time, money, and prevents customs holds!
β¨ Professional clearance starts with precise classification!
πΌ Your profit margin depends on every percentage point!
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About HS Code Classification
The Harmonized System (HS) is an internationally standardized nomenclature developed by the World Customs Organization (WCO) to classify traded products. Over 200 countries use the HS system as the basis for customs tariffs, trade statistics, and import/export regulations.
Each HS code follows a hierarchical structure:
- Chapter (2 digits) β Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) β More specific grouping within the chapter
- Subheading (6 digits) β Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) β Country-specific extensions for further classification, such as US HTSUS 10-digit codes
Correct HS code classification is essential for smooth customs clearance, accurate duty payment, and compliance with trade regulations. Misclassification can lead to customs delays, overpayment of duties, or penalties.
When importing from CN to US, the applicable tariff rates may include:
- Most-Favored-Nation (MFN) rate β The standard duty rate applied to WTO members
- General rate β Applied to countries without trade agreements
- Trade remedy duties β Additional tariffs such as Section 301 (anti-dumping), Section 232 (national security), or countervailing duties
The information provided on this page is for reference purposes only. For official classification, please consult with your local customs authority or a licensed customs broker.