Bovine leather splits for cushions
CN โ US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 9401991010 | 17.5% | CN | US | Official Doc |
| 9401104000 | 17.5% | CN | US | Official Doc |
| 4205008000 | 35.0% | CN | US | Official Doc |
| 4205006000 | 39.9% | CN | US | Official Doc |
| 4202919090 | 39.5% | CN | US | Official Doc |
AI Analysis
๐๏ธ Bovine Leather Splits for Cushions (็็ฎๅบงๆค /็ฎ้ฉ้จไปถ)
๐ HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
๐ Part 1: Product Definition & Classification: Are You Classifying "Leather" or "Furniture"?
Bovine leather splits intended for cushions represent a critical classification trap in international trade. The core dispute lies in distinguishing between semi-finished leather products (Chapter 42) and finished furniture parts (Chapter 94). The physical form, functional readiness, and integration determine the HS Code.
Bovine Leather Splits (Raw/Semi-finished):
Cut pieces of split cowhide, not yet shaped into a complete seat or upholstered. They are treated as "articles of leather."
Finished Seat Components/Seats:
Items that are specifically shaped, stitched, or padded to function as a seat or a major component of a seat (e.g., leather upholstery kits pre-cut for a car seat).
โ ๏ธ Key Distinction Point:
- If the leather is merely a material/raw good intended for further manufacturing (e.g., generic cuttings for upholstery) โๅฝๅ ฅ 4205 or 4202 (Leather Articles).
- If the item is specifically shaped/configured for a seat (e.g., "Leather Seat Cover for Automotive Use" or "Leather Seat Parts") โๅฝๅ ฅ 9401.99.10.10 or 9401.10.40.00 (Furniture Parts).
๐ฆ Part 2: HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
| HS Code | Product Description | Applicable Scenario | Basis for Classification |
|---|---|---|---|
9401.99.10.10 |
Leather Seats, matching leather material and seat usage | Finished seat covers, pre-assembled seat components, automotive seat leather parts | โ Furniture Part (Specific to seats) |
9401.10.40.00 |
Leather Seats, matching leather material and seat form | Seats with leather upholstery, shaped seat cushions, automotive seating units | โ Furniture Item (Specific form) |
4205.00.80.00 |
Leather Articles, matching leather material and other leather articles classification | Generic leather cuttings, straps, or non-specific leather goods for cushion stuffing or covering | โ Material/Accessory (General leather) |
4205.00.60.00 |
Leather Articles, matching leather material and other leather articles scope | Similar to above, but potentially different duty base due to specific sub-category nuances | โ Material/Accessory (General leather) |
4202.91.90.90 |
Articles of Leather, based on material consistency | Outer surface leather articles not elsewhere specified, generic leather sheets | โ Material (General leather) |
๐ Key Reminder:
- Chapter 94 (Furniture) applies when the item is recognizably a part of furniture (specifically seats). The description "Bovine leather splits for cushions" often implies a seat component. - Chapter 42 (Leather Articles) applies if the item is considered a generic leather product not specifically designed as a seat part (e.g., raw split leather sheets). - Misclassification Risk: Classifying a seat-specific part as generic leather (4205/4202) to save duty is high-risk if the item is clearly shaped for seats.
๐ฐ Part 3: 2026 Latest Tariff Rate Breakdown (Including Additional Taxes, Policy Surcharges)
โ Applicable Country: United States (US)
โ Country of Origin: China (CN)
โ Effective Date: From November 10, 2025 (inclusive of subsequent imports)
๐ฏ 1. 9401.99.10.10 & 9401.10.40.00 โ Leather Seats / Seat Parts
| Item | Content |
|---|---|
| Base Duty Rate | 0.0% (Ad Valorem) |
| Section 301 Additional Duty | +7.5% |
| Section 122 Tariff | +10% (Specific to certain leather/furniture items under IEEPA/Trade Act provisions) |
| Total Effective Rate | 17.5% |
| Tax Calculation | CIF Value ร 17.5% |
| De Minimis Eligibility | โ Not Eligible (Deny De Minimis for Section 301/122 items) |
| Legal Basis Path | USITC:9401.99.10.10 โ Section 301: Footnote 9903.xx โ Section 122: Tariff Act |
๐ Explanation:
- These codes fall under Furniture Parts. While the base duty is low (0%), the Section 301 tariff (7.5%) and Section 122 tariff (10%) are significant additions. - Total 17.5% is the effective cost for seat-specific leather items.
๐ฏ 2. 4205.00.80.00 โ Generic Leather Articles (Split Leather)
| Item | Content |
|---|---|
| Base Duty Rate | 0.0% |
| Section 301 Additional Duty | +25.0% |
| Section 122 Tariff | +10% |
| Total Effective Rate | 35.0% |
| Tax Calculation | CIF Value ร 35.0% |
| De Minimis Eligibility | โ Not Eligible |
| Legal Basis Path | USITC:4205.00.80.00 โ Section 301 โ Section 122 |
๐ Explanation:
- If classified as generic leather articles (Chapter 42), the Section 301 tariff is higher (25%) compared to furniture parts (7.5%). - Total 35.0% is significantly more expensive. This is why correct classification as 9401 (Seat Parts) is crucial for cost savings, provided the item qualifies as a seat component.
๐ฏ 3. 4205.00.60.00 โ Other Leather Articles
| Item | Content |
|---|---|
| Base Duty Rate | 4.9% |
| Section 301 Additional Duty | +25.0% |
| Section 122 Tariff | +10% |
| Total Effective Rate | 39.9% |
| Tax Calculation | CIF Value ร 39.9% |
| De Minimis Eligibility | โ Not Eligible |
๐ฏ 4. 4202.91.90.90 โ General Leather Articles
| Item | Content |
|---|---|
| Base Duty Rate | 4.5% |
| Section 301 Additional Duty | +25.0% |
| Section 122 Tariff | +10% |
| Total Effective Rate | 39.5% |
| Tax Calculation | CIF Value ร 39.5% |
| De Minimis Eligibility | โ Not Eligible |
๐ ๏ธ Part 4: Customs Clearance Practical Advice (Combat Pitfalls Guide)
โ 1. Documentation Checklist (Non-Negotiable)
| Document | Required | Description |
|---|---|---|
| โ Product Specifications | โ๏ธ | Detail if the leather is "raw split," "pre-cut," "shaped for seats," or "upholstered." |
| โ Product Photos | โ๏ธ | Show the leatherโs shape. If it has contours/stitches for a seat, it supports 9401. If flat/generic, it supports 4205. |
| โ Commercial Invoice | โ๏ธ | Clearly state: "Leather Seat Parts for Automotive/Upholstery" (for 9401) OR "Bovine Leather Splits for General Use" (for 4205). |
| โ Packing List | โ๏ธ | Indicate if items are packed as seat components or bulk leather rolls/sheets. |
| โ Certificate of Origin | โ๏ธ | Standard requirement for US imports. |
โ 2. Declaration Strategy (Key Mnemonic)
๐ฅ "Shape Dictates Code, 9401 Saves Duty!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Leather cut/shaped specifically for car/office seats | 9401.99.10.10 or 9401.10.40.00 |
Misclassifying as 4205 โ 35% tax |
| Flat, generic leather splits for upholstery manufacturing | 4205.00.80.00 |
Misclassifying as 9401 โ Risk of audit for "not furniture parts" |
| Upholstered cushions (fully assembled) | Check if itโs a "Seat" or "Article of Furniture" | Incorrectly using general leather codes |
๐ Critical Tip:
- If the leather is pre-shaped, stitched, or padded to function as a seat or seat part, always aim for 9401. - If it is raw, flat, or generic cuttings, use 4205, but accept the higher 35% tax. - Do not misdeclare seat parts as "leather rolls" to avoid the 7.5% Section 301 tax. US Customs (CBP) frequently audits leather imports for this discrepancy.
โ 3. Special Case Handling
| Scenario | Recommendation |
|---|---|
| OEM Seat Covers | Provide the OEM part number and car model. Clearly label as "Automotive Seat Cover." |
| Mixed Shipment (Leather + Seat Parts) | Declare separately. Do not bundle under one HS Code. |
| Small Samples | Even samples are subject to the same tariff classification if they are functional seat parts. |
๐ Part 5: Global Market Comparison (2026 Update)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Key Requirement | Note |
|---|---|---|---|---|
| ๐บ๐ธ USA | 9401.99.10.10 |
17.5% (with Sec 301 & 122) | FCC/No FCC (if electronic), Standard Compliance | Lower tax than Chapter 42 (35%) |
| ๐จ๐ณ China | 9401.99.10.10 |
~5-10% | CCC (if applicable) | Lower base duty |
| ๐ช๐บ EU | 9401.90.00 |
~0-4% (Varies) | CE (if furniture), REACH (Leather) | No Section 301 equivalent |
| ๐ฌ๐ง UK | 9401.90.00 |
~0-4% | UKCA | Post-Brexit rules apply |
๐ Conclusion:
- USA is the most critical market due to Section 301 and Section 122 tariffs. - Correctly classifying as 9401 (Seat Parts) instead of 4205 (Leather Articles) saves 17.5% in duty (17.5% vs. 35%). - Prove "Seat-Readiness": Use photos, specs, and invoicing that highlight the productโs function as a seat component to justify the 9401 classification.
๐ Part 6: Common Errors & Pitfalls (Lessons Learned)
โ Error 1: Declaring shaped leather seat parts as "Leather Rolls" (4205)
๐ Consequence: CBP audit โ Forced reclassification to 9401 + Penalties + Back Taxes.
๐ Reality: 9401 is cheaper (17.5% vs. 35%). Why risk it?
โ Error 2: Declaring generic leather splits as "Seat Parts" (9401)
๐ Consequence: CBP rejects as "misdeclaration" because the item lacks seat-specific features.
๐ Reality: If itโs not shaped for seats, use 4205.
โ Error 3: Ignoring Section 122 Tariff
๐ Consequence: Underpayment of 10% on all these codes.
๐ Reality: Section 122 applies to both 9401 and 4205. Always include it.
โ Correct Practice:
"Automotive Leather Seat Cover, Pre-Cut and Stitched, Model XYZ, for US Market, HS 9401.99.10.10"
๐ฏ Part 7: Conclusion: Professional Classification, Cost Savings!
๐ฏ Remember the Mnemonic:
๐น "Seat-Shape = 9401 (17.5%), Generic Leather = 4205 (35%)."
๐น "Donโt Overpay! Prove itโs a Seat Part!"
๐ Pro Tip:
If your leather is generic but you want to avoid the 35% tax, consider if it can be pre-assembled or shaped before export to justify 9401. However, do not misrepresent the product.
Apply for a CBP Binding Ruling if unsure. Itโs the only way to guarantee classification and avoid post-entry audits.
๐ฃ Immediate Action:
๐ Consult a licensed customs broker.
๐ท Provide photos of the shaped leather to support 9401 classification.
๐ Save 17.5% per CIF value by correct classification!
โจ Professional Customs Clearance Starts with Precise Classification!
๐ผ Every Percent Saved is Profit Earned!
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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) โ Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) โ More specific grouping within the chapter
- Subheading (6 digits) โ Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) โ 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 โ The standard duty rate applied to WTO members
- General rate โ Applied to countries without trade agreements
- Trade remedy duties โ 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.