Cleaning Clay
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 2530908050 | 10.0% | CN | US | Official Doc |
| 3307900000 | 40.4% | CN | US | Official Doc |
| 3401115000 | 35.0% | CN | US | Official Doc |
| 2530908015 | 10.0% | CN | US | Official Doc |
| 3307305000 | 39.9% | CN | US | Official Doc |
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πΏ Cleaning Clay: HS Code Classification & Customs Clearance Strategy (2026 Update)
π HS Code Reference & Customs Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "Cleaning Clay"?
Cleaning Clay (also known as facial mud, bath mud, or clay masks) is a versatile cosmetic and mineral product. In international trade, its classification is highly controversial because it sits at the intersection of minerals and cosmetics. The final HS Code depends entirely on the primary function, composition, and marketing intent.
β οΈ Key Distinction Points:
- If the product is primarily a raw mineral substance with minimal processing β May fall under Chapter 25 (Mineral Products).
- If the product is prepared for personal hygiene, beauty, or bathing β Must fall under Chapter 33 (Essential Oils, Cosmetics).
- Do NOT classify based on shape alone (e.g., "paste" does not automatically mean soap).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority)
Based on the provided data, here are the five potential HS Codes for Cleaning Clay, along with their legal justifications and tax implications.
| HS Code | Product Description | Classification Logic | Total Tax Rate (China Origin β US) |
|---|---|---|---|
2530.90.80.50 |
Other prepared binding agents of mineral substances; Other mineral substances | Classified as a mineral due to its mud-like form. Assumes minimal processing beyond basic preparation. | 10.0% |
3307.90.00.00 |
Other perfumed or cosmetic preparations | Classified as a cosmetic/toilet preparation. Fits the scope of other scented, cosmetic, or toilet preparations not elsewhere specified. | 40.4% |
3401.11.50.00 |
Soaps and organic surface-active products for skin cleansing; Molded/Bar/Paste Forms | Classified as a soap/cleansing agent. Assumes it falls under molded/paste forms of organic surface-active products. | 35.0% |
2530.90.80.15 |
Other mineral substances (including mineral pigments) | Classified as a mineral substance. Assumes the clay is inferred as a mineral pigment or raw mineral material based on its mud-like state. | 10.0% |
3307.30.50.00 |
Bath preparations (e.g., bath salts, powders) | Classified as a bath preparation. Logic follows similar hygiene products like scented bath salts. | 39.9% |
π Critical Analysis:
- Lowest Tax Strategy:2530.90.80.50or2530.90.80.15at 10%. Risk: Customs may reject this if the product contains added fragrances, preservatives, or active cosmetic ingredients, reclassifying it as Chapter 33.
- Most Likely Compliance:3307.90.00.00or3307.30.50.00at ~40%. Why? Most commercial "cleaning clays" for consumer use are formulated for skin health/beauty, making Chapter 33 the stricter, safer legal interpretation.
- Middle Ground:3401.11.50.00at 35%. Risk: Only applicable if the product strictly meets the definition of "soap/surface-active agent" in paste form.
π° III. 2026 Detailed Tariff Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: From November 10, 2025 (including subsequent imports)
π― 1. Mineral-Based Classifications (2530.90.80.50 & 2530.90.80.15)
Best for: Raw, unperfumed, pure mineral clays.
| Item | Content |
|---|---|
| Base Tariff | 0% (ad valorem) |
| USITC Surcharge | 0% |
| Section 122 Tariff | +10% (Specific to these subheadings in the provided data) |
| Total Tax Rate | 10.0% |
| Tax Calculation | CIF Value Γ 10% |
| De Minimis Exemption | β Not Applicable (Section 122 tariffs usually apply regardless of shipment value for this category) |
| Legal Basis Path | USITC:2530.90.80 β SECTION_122:10% |
π Explanation:
- The 10% rate comes from specific "Section 122" tariffs applied to certain mineral products.
- No Section 301 (25%) is applied here in the provided data.
- Warning: If Customs determines the clay is "cosmetic," this 10% rate is void, and you will owe back-taxes at the 40% rate.
π― 2. Cosmetic/Toilet Preparations (3307.90.00.00)
Best for: Standard facial masks, beauty clays with fragrances.
| Item | Content |
|---|---|
| Base Tariff | 5.4% |
| Section 301 Surcharge | +25.0% (USITC Footnote 9903.07) |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 40.4% |
| Tax Calculation | CIF Value Γ 40.4% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis Path | IEEPA:9903.07 β USITC:3307.90.00.00 β FOOTNOTE:9903.07 |
π Explanation:
- This is the standard high-tax bracket for cosmetics from China.
- Includes Base + Section 301 (25%) + Section 122 (10%).
- High Risk: Any misclassification here can lead to significant duty underpayment penalties.
π― 3. Soap/Cleansing Agents (3401.11.50.00)
Best for: Paste-form clays marketed strictly as "cleansing bars/pastes."
| Item | Content |
|---|---|
| Base Tariff | 0.0% |
| Section 301 Surcharge | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis Path | IEEPA:9903.07 β USITC:3401.11.50.00 |
π Explanation:
- Slightly lower than cosmetics due to 0% base rate.
- However, Chapter 34 requires the product to be primarily "soap" or "surface-active." If it's mostly inert clay, this classification is vulnerable to challenge.
π― 4. Bath Preparations (3307.30.50.00)
Best for: Bath muds, soak clays.
| Item | Content |
|---|---|
| Base Tariff | 4.9% |
| Section 301 Surcharge | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 39.9% |
| Tax Calculation | CIF Value Γ 39.9% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis Path | IEEPA:9903.07 β USITC:3307.30.50.00 |
π Explanation:
- Very similar to general cosmetics. Use only if the product is explicitly marketed for bathing/soaking, not facial cleansing.
π οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
β 1. Documentation Checklist (Non-Negotiable)
| Document | Required? | Notes |
|---|---|---|
| β Ingredient List | βοΈ | Must detail % of mineral vs. active cosmetic ingredients. |
| β Product Label/Photo | βοΈ | Shows marketing claims ("Facial Mask" vs. "Mineral Raw Material"). |
| β Statement of Composition | βοΈ | Explicitly state if it is "perfumed," "medicated," or "raw mineral." |
| β Commercial Invoice | βοΈ | Clearly describe as "Natural Clay" or "Cosmetic Clay Mask," not vague "Clay." |
| β MSDS (Safety Data Sheet) | βοΈ | Required for chemical/mineral classification verification. |
| β Third-Party Lab Report | β Optional | Recommended if challenging classification (proves mineral content). |
β 2. Declaration Strategy (Key Mantra)
π₯ "Form follows Function, Function determines Chapter, Chapter dictates Tax!"
| Scenario | Correct HS Code | Incorrect HS Code | Consequence |
|---|---|---|---|
| Pure, raw bentonite clay (no scent, no additives) | 2530.90.80.50 (10%) |
3307.90.00.00 (40.4%) |
Overpaid Tax (Refund possible) |
| Scented Facial Clay Mask (cosmetic use) | 3307.90.00.00 (40.4%) |
2530.90.80.50 (10%) |
Underpaid Tax + Penalties |
| Bath Mud (soaking use) | 3307.30.50.00 (39.9%) |
2530.90.80.50 (10%) |
Audit Risk |
| Clay Paste (marketed as soap/cleanser) | 3401.11.50.00 (35.0%) |
3307.90.00.00 (40.4%) |
Savings if approved |
β 3. Special Situation Handling
| Situation | Recommendation |
|---|---|
| OEM Private Label | Ensure the supplierβs HS code matches your marketing. If they say "Mineral" but you sell as "Beauty Mask," Customs will reclassify. |
| Mixed Shipment | If shipping pure clay AND scented masks together, declare separately. Do not mix Chapter 25 and Chapter 33 in one line item. |
| Claiming "Mineral" Status | You MUST provide proof that no cosmetic active ingredients (like salicylic acid, fragrances, or preservatives) are added. Otherwise, Chapter 33 applies. |
| Section 122 vs 301 | Note that Section 122 (10%) is additional to base/301 rates in cosmetic categories. It is NOT a replacement. |
π V. Global Market Comparison (2026 Update)
| Country/Region | Recommended HS Code | Est. Tariff (China Origin) | Key Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3307.90.00.00 |
40.4% | FDA Registration (Cosmetics) | High risk of reclassification to Chapter 25 if unperfumed. |
| π¨π³ China | 3307.90.00.00 |
~6-10% | NMPA Registration | Lower base rate, but strict cosmetic regulations. |
| πͺπΊ EU | 3307.90.00 |
0% (if compliant) | CPNP Notification | No Section 301/122. Strict safety assessments required. |
| π¬π§ UK | 3307.90.00 |
0% (if compliant) | UK CPNP | Post-Brexit rules, but generally lower tariffs for cosmetics. |
| π―π΅ Japan | 3307.90.00 |
4.8% | FSC Notification | Low base tariff, but complex cosmetic labeling laws. |
π Conclusion:
- USA is the most expensive market due to Section 301 (25%) + Section 122 (10%) + Base Rate.
- Mineral classification (10%) is only viable if the product is truly raw/unprocessed.
- For cosmetic clays, the 40%+ rate is unavoidable in the US market.
π VI. Common Errors & Pitfalls (Lessons Learned)
β Mistake 1: Calling it "Clay" without specifying type.
π Result: Customs may default to the highest tax rate or request manual examination.
β
Fix: Use "Natural Bentonite Clay" or "Cosmetic Clay Mask."
β Mistake 2: Declaring scented clay as "Mineral" to save tax.
π Result: Severe Penalty. Customs will detect fragrance components and reclassify as Chapter 33.
β
Fix: Be honest. If it has scent, itβs Chapter 33.
β Mistake 3: Ignoring Section 122 Tariffs.
π Result: Underpayment of 10% on all shipments.
β
Fix: Check if Section 122 applies to your specific subheading (it does for all codes in the provided data).
π― VII. Conclusion: Professional Declaration, Cost Optimization!
π― Remember the Mantra:
πΉ "Raw & Plain? Chapter 25 (10%). Scented & Beauty? Chapter 33 (40%)."
πΉ "Don't Gamble with 'Clay'βCustoms Knows the Difference!"
π Pro Tip:
If you are importing large volumes of unperfumed, pure mineral clay, apply for an Advance Ruling from CBP to confirm Chapter 25 classification. This provides legal certainty and protects your profit margin.
π£ Immediate Action:
π Consult a Customs Broker + Submit Ingredient Analysis + Verify Marketing Claims.
π Ensure Your Compliance Matches Your Product!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Percentage Point Counts in 2026!
Customer Reviews
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.