Cleaner with Aromatic Modifiers
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3402901000 | 38.8% | CN | US | Official Doc |
| 3810905000 | 40.0% | CN | US | Official Doc |
| 3810100000 | 40.0% | CN | US | Official Doc |
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π§ͺ Cleaner with Aromatic Modifiers (Descaling Agents / Chemical Cleaners)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π Part I: Product Definition & Classification: What Exactly is "Cleaner with Aromatic Modifiers"?
"Cleaner with Aromatic Modifiers," commonly referred to in industrial contexts as Descalers or Chemical Cleaning Agents, are specialized formulations designed to remove mineral deposits (limescale, rust, grease) from surfaces. In international trade, the classification depends heavily on its primary function and chemical composition.
These products generally fall into two main categories in the HS Code system: 1. Surface Active Agents / Surfactant Preparations: If the primary action is foaming, wetting, or emulsifying grease/dirt via chemical surfactants. 2. Metal Surface Treatment / Acid Preparations: If the primary action is chemical etching, acid washing, or descaling using acidic components.
β οΈ Key Distinction Point: - If the product is primarily a surfactant-based detergent for general cleaning β Likely 3402.90.10.00 - If the product is primarily an acidic descaler or metal surface treatment agent β Likely 3810.90.50.00 or 3810.10.00.00
π¦ Part II: HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Applicability | Tax Detail Summary |
|---|---|---|---|
3402.90.10.00 |
Descalers belong to chemical cleaning agents/surfactant preparations; functional attributes match synthetic detergents | General chemical cleaners, surfactant-based descaling agents | Total Tax: 38.8% (Base: 3.8%, Add-on: 25.0%, Section 122: 10%) |
3810.90.50.00 |
Descalers belong to metal surface treatment or cleaning chemicals, fitting the nature of other auxiliary preparations | Metal surface cleaning, non-specific chemical auxiliaries | Total Tax: 40.0% (Base: 5.0%, Add-on: 25.0%, Section 122: 10%) |
3810.10.00.00 |
Descalers usually contain acidic components, belonging to metal surface pickling/chemical preparation category | Acidic descachers, rust removers, pickling agents | Total Tax: 40.0% (Base: 5.0%, Add-on: 25.0%, Section 122: 10%) |
π Critical Reminder: - Surfactant-based cleaners (foaming, emulsifying) should be classified under 3402.90.10.00. - Acid-based or metal-specific cleaners should be classified under 3810 series codes. - Misclassification can lead to significant duty differences and customs delays.
π° Part III: 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: November 10, 2025 (and subsequent imports)
π― 1. 3402.90.10.00 ββ Surfactant Preparations (General Chemical Cleaners)
| Item | Content |
|---|---|
| Base Tariff | 3.8% (ad valorem) |
| USITC Surcharge | +25% (Under USITC Footnote provisions for Section 301) |
| IEEPA Surcharge | +10% (Targeting China/HK products, effective from Nov 10, 2025, under Section 122/IEEPA) |
| Total Tax Rate | 38.8% |
| Tax Calculation | CIF Value Γ 38.8% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis applies to Section 301/122 goods) |
| Legal Basis Path | USITC:3402.90.10.00 β SECTION301:25% β IEEPA:10% |
π Explanation: - The "Base Tariff of 3.8%" is the standard Most Favored Nation (MFN) rate for surface-active agents. - The "25% USITC Surcharge" is applied due to Section 301 trade remedies against China. - The "10% IEEPA/Section 122 Surcharge" is an additional layer for specific Chinese imports. - Total 38.8% is a high tariff rate, requiring strict cost control and accurate declaration.
π― 2. 3810.90.50.00 ββ Metal Surface Treatment/Other Auxiliary Preparations
| Item | Content |
|---|---|
| Base Tariff | 5.0% (ad valorem) |
| USITC Surcharge | +25% (Under USITC Footnote provisions for Section 301) |
| IEEPA Surcharge | +10% (Targeting China/HK products, effective from Nov 10, 2025) |
| Total Tax Rate | 40.0% |
| Tax Calculation | CIF Value Γ 40.0% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis applies) |
| Legal Basis Path | USITC:3810.90.50.00 β SECTION301:25% β IEEPA:10% |
π Note: - This code applies to cleaning agents that are not primarily surfactants but serve as auxiliary treatments for metals. - The rate is slightly higher than 3402 due to a higher base tariff (5.0% vs 3.8%), but the surcharges are identical.
π― 3. 3810.10.00.00 ββ Metal Surface Pickling/Acidic Chemical Preparations
| Item | Content |
|---|---|
| Base Tariff | 5.0% (ad valorem) |
| USITC Surcharge | +25% (Under USITC Footnote provisions for Section 301) |
| IEEPA Surcharge | +10% (Targeting China/HK products, effective from Nov 10, 2025) |
| Total Tax Rate | 40.0% |
| Tax Calculation | CIF Value Γ 40.0% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis applies) |
| Legal Basis Path | USITC:3810.10.00.00 β SECTION301:25% β IEEPA:10% |
π Note: - This code is specific for acidic descachers and pickling agents. - Crucial: If the product contains strong acids (e.g., hydrochloric, phosphoric), it must be declared under this code or 3810.90.50.00, not 3402. Misclassifying an acidic descaler as a general surfactant is a major compliance risk.
π οΈ Part IV: Customs Clearance Practical Advice (Real-World Pitfall Avoidance Guide)
β 1. Document Checklist (All Required)
| Document | Mandatory | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must detail chemical composition, pH value, primary active ingredients (surfactant vs. acid). |
| β Safety Data Sheet (SDS) | βοΈ | Critical for hazardous chemicals. Must indicate if it's corrosive or flammable. |
| β Product Photos (with Label) | βοΈ | Clear view of ingredient list, brand, and usage instructions. |
| β Third-Party Test Report | βοΈ | pH level, heavy metal content, biodegradability (if claimed). |
| β Commercial Invoice | βοΈ | Must accurately describe the product as "Descaling Agent" or "Chemical Cleaner," avoiding vague terms like "Cleaning Solution." |
| β Packing List | βοΈ | Detail net/gross weight, volume, and container type (e.g., IBC tote, drum, bottle). |
β 2. Declaration Tips (Key Mnemonics)
π₯ βAcid goes to 3810, Surfactant to 3402. Name matters, Tax changes!β
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Acidic Descaler (e.g., for boilers, rust) | 3810.10.00.00 or 3810.90.50.00 |
Misdeclare as 3402.90.10.00 β 40% vs 38.8% + Compliance Risk |
| General Detergent with Fragrance | 3402.90.10.00 |
Misdeclare as 3810 β 38.8% vs 40% + Potential Penalty |
| "Aromatic Modifiers" as Additive | Disclose as part of formulation | Do not declare "Aromatic Modifiers" as the main product name |
| Bulk Chemical Shipments | Declare by Volume/Weight | Avoid declaring by "pieces" if it's a bulk liquid |
β 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| Highly Corrosive (Acidic) | Must provide detailed SDS. Customs may require additional safety inspections. |
| Fragrant/Aromatic Claim | If "aromatic" is just a scent additive, it does not change the HS code. Ensure the primary function (cleaning/descaling) is clear. |
| Mixed Packaging | If sold in small bottles for consumer use vs. bulk drums for industrial use, the HS code remains the same, but packaging details must match. |
| Pre-Clearance Ruling | Strongly recommended for high-volume imports to avoid classification disputes. |
π Part V: Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3402.90.10.00 or 3810.xx |
38.8% - 40.0% | EPA (if pesticidal), TSCA | High tariffs due to Section 301 & 122. |
| π¨π³ China | 3402.90.10.00 or 3810.xx |
~5-6% | None specific for import (domestic use) | Lower duty burden. |
| πͺπΊ EU | 3402.90.90 or 3810.xx |
0-6.5% | REACH, CLP Labeling | No Section 301 equivalent, but REACH compliance is strict. |
| π¬π§ UK | 3402.90.90 or 3810.xx |
0-6.5% | UK REACH | Similar to EU post-Brexit. |
| π¦πΊ Australia | 3402.90.90 or 3810.xx |
5% | AICIS | Moderate duty, no surcharges. |
π Conclusion: - USA is the most challenging market due to the 38.8%-40% effective tariff rate. - EU/UK/Australia offer lower duty rates but require strict chemical compliance (REACH/CLP/AICIS). - China has lower duties, so sourcing from non-Chinese origins may help avoid the 35%+ surcharges if eligible.
π Part VI: Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Declaring an acidic descaler as a general detergent (3402)
π Consequence: Underpayment of 1.2% tax + customs penalty for misclassification + potential hazardous material violation.
β Error 2: Ignoring the "Aromatic Modifiers" component in the name π Consequence: If the product is primarily a fragrance carrier with cleaning properties, it might still be classified under 3402, but if the cleaning agent is secondary, it could be reclassified as a perfume/cosmetic (different duty). Ensure the primary function is "cleaning."
β Error 3: Failing to disclose Section 301/122 Applicability π Consequence: If the product is from China, failing to pay the additional 35% (25%+10%) will result in seizure, fines, and back taxes.
β Error 4: Vague Description ("Chemical Cleaner") π Consequence: Customs will ask for more information, causing delays. Be specific: "Acidic Descaling Agent for Industrial Equipment, pH 2, Contains Citric Acid."
β Correct Approach:
"Descaling Agent, Acidic Formulation, Contains Citric Acid & Surfactants, for Industrial Boilers, SDS Available, HS Code 3810.10.00.00"
π― Part VII: Conclusion: Precision Classification Saves Money!
π― Remember the Mnemonic:
πΉ "Acid = 3810 (40%), Surfactant = 3402 (38.8%). Don't Guess, Check SDS!"
πΉ "US Market = High Tax (35%+), EU Market = High Compliance (REACH)."
πΉ "Misclassification = Penalty + Delay + Back Tax."
π Pro Tip:
If your cleaner is originating from Vietnam, Malaysia, or Thailand, you may avoid the US Section 301/122 surcharges, reducing the total tariff to just the base rate (3.8%-5.0%). Consider supply chain diversification or transshipment with substantial transformation to mitigate high US tariffs.
π£ Immediate Action:
π Consult a licensed customs broker + Provide SDS + Apply for Advance Ruling from CBP. π Ensure your cleaner clears customs smoothly, complies with regulations, and maximizes profit margins!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every cent in duty is worth calculating precisely!
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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.