Cold Compress Patch (20 pieces)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3005101000 | 10.0% | CN | US | Official Doc |
| 3005901000 | 10.0% | CN | US | Official Doc |
| 3005105000 | 10.0% | CN | US | Official Doc |
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AI Analysis
βοΈ Cold Compress Patch (20 pieces)
π HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy
π I. Product Definition & Classification: What exactly is a "Cold Compress Patch"?
Cold compress patches, often marketed as "heat relief patches" or "cooling gel packs," are adhesive medical or nursing products designed to lower surface temperature for fever reduction, pain relief, or injury care. In international trade, their classification depends strictly on their composition, function, and presence of medicated coatings.
Key Distinction:
- Non-Medicated Physical Cooling Pads: Purely physical cooling effect, often using hydrogel or superabsorbent polymers. If they have an adhesive backing but no active pharmaceutical ingredient (API) coating, they may fall under general medical dressings.
- Medicated/Cooling Agent Infused Pads: Contain chemical agents (e.g., menthol, camphor, or specific cooling chemicals) that provide a pharmacological or chemical cooling effect. These are strictly classified as medical dressings impregnated with pharmaceutical substances.
β οΈ Critical Classification Point:
- If the patch is adhesive and contains a medicated or chemical cooling coating β It is classified under Chapter 30 (Pharmaceutical Products), specifically as Medical Dressings.
- If it is non-adhesive and used merely as a physical compress without drugs/chemicals β It might fall under Chapter 30 or 39/59 depending on material, but most commercial "cold patches" with adhesive backs and cooling gels are treated as medicated dressings.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority)
Based on the provided data, here are the specific HS codes and their explanations for Cold Compress Patches:
| HS Code | Product Description | Application Scenario | Material/Feature |
|---|---|---|---|
3005.10.10.00 |
Cold compress patches with adhesive layer or dressing nature, for medical/nursing use, containing medicated or chemical coating. | Standard adhesive cooling patches for fever/pain relief. | β Contains adhesive & chemical/medicated coating. |
3005.90.10.00 |
Antipyretic/Cold compress patches; similar articles impregnated or coated with medicaments, made of cotton, gauze, or other fibrous materials. | Patches made of cotton/gauze base with cooling agents. | β Fibrous base (cotton/gauze) + medicated coating. |
3005.10.50.00 |
Cold compress patches classified as dressings, made of cotton/non-woven fabric containing medicated or cooling components, meeting medical/surgical dressing characteristics. | Medical-grade cold pads for surgical or post-op care. | β Non-woven/cotton base + cooling component + adhesive/dressing nature. |
π Key Reminder:
- All three codes listed below carry a total tax rate of 10.0% due to Section 122 Tariff provisions.
- The core differentiator is the base material (adhesive-only vs. fibrous/cotton vs. non-woven medical grade) and the specific type of dressing.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: 2025-11-10 (and subsequent imports)
π― 1. 3005.10.10.00 ββ Adhesive Cold Compress Patches with Medicated/Chemical Coating
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% (ad valorem) |
| Section 301 Surcharge | 0.0% (Specific footnote may apply, but data indicates 0%) |
| Section 122 Tariff | +10.0% (232/301 related or specific trade remedy) |
| Total Tax Rate | 10.0% |
| Tax Calculation | CIF Value Γ 10% |
| De Minimis Eligibility | β Not Eligible (Section 321 de minimis often excluded for Section 122/301 goods from China depending on current enforcement, but strictly speaking, Section 122 items are high-risk for de minimis abuse checks). Note: Data implies strict taxation. |
| Legal Basis Path | HTSUS:3005.10.10.00 β Section 122 Tariff: 10% |
π Explanation:
- Base Rate: 0% for most medical dressings.
- Section 122 Tariff: This is a critical surcharge. Section 122 typically refers to specific trade enforcement actions. For Chinese-origin goods, a 10% additional tariff is applied.
- Total Cost Impact: A $1,000 shipment incurs $100 in duties.
π― 2. 3005.90.10.00 ββ Cotton/Gauze-Based Medicated Cold Patches
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% |
| Section 301 Surcharge | 0.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 10.0% |
| Tax Calculation | CIF Value Γ 10% |
| De Minimis Eligibility | β Not Eligible (High risk of audit for Section 122 goods). |
| Legal Basis Path | HTSUS:3005.90.10.00 β Section 122 Tariff: 10% |
π Explanation:
- Applies to patches using traditional fibrous materials (cotton/gauze) as the base, coated with cooling medicaments.
- Same tariff structure as above.
π― 3. 3005.10.50.00 ββ Medical-Grade Non-Woven/Cotton Cold Dressings
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% |
| Section 301 Surcharge | 0.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 10.0% |
| Tax Calculation | CIF Value Γ 10% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | HTSUS:3005.10.50.00 β Section 122 Tariff: 10% |
π Explanation:
- Specifically for products that meet the definition of medical/surgical dressings (non-woven or cotton) with cooling/medicated components.
- Often used in hospitals or professional care settings.
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (No Exceptions)
| Document | Mandatory? | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must detail: Material (cotton/non-woven/adhesive), Active Ingredients (e.g., Menthol, Water, Glycerin), Adhesive Type. |
| β Ingredient List (INCI) | βοΈ | Crucial to prove if it's "medicated/chemically coated" vs. "physical only." |
| β Labeling Copy | βοΈ | Must show intended use (e.g., "For External Use Only," "Not for Break Skin"). |
| β FDA Registration (if applicable) | βοΈ | If marketed as a medical device (Class I or II), FDA establishment registration may be required. |
| β Commercial Invoice | βοΈ | Must clearly state: "Cold Compress Patches, HS Code 3005.xx, Origin China." |
| β Certificate of Origin | βοΈ | Proves origin to apply correct Section 122 rates. |
| β Free Sale Certificate | βοΈ | Often required for medical/nursing products. |
β 2. Declaration Tips (Key Mantra)
π₯ βDeclare Medication, Specify Material, Avoid βPhysicalβ Traps!β
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Standard Adhesive Patch | 3005.10.10.00 - "Adhesive medical dressing, impregnated with cooling agents." |
Calling it "Cooling Gel Mask" β Might be misclassified as cosmetics (higher risk). |
| Cotton/Gauze Patch | 3005.90.10.00 - "Fibrous dressing, cotton-based, medicated." |
Calling it "Wet Towel" β Misclassification. |
| Medical Grade Pad | 3005.10.50.00 - "Surgical dressing, non-woven, cooling component." |
Calling it "Bandage" β Too vague. |
| Non-Medicated (Pure Water Gel) | β οΈ High Risk | If truly non-medicated, it might fall under Chapter 39/59, but customs often presume medicated. Consult specialist. |
β 3. Special Handling for Section 122
| Situation | Handling Advice |
|---|---|
| Section 122 Applicability | Ensure your supplier confirms the product is not exempt. Most Chinese-made consumer health products are subject to this 10% surcharge. |
| De Minimis (Section 321) | Do NOT rely on $800 de minimis exemption for these HS codes if they are flagged under Section 122. Customs may audit and demand full duties + penalties. |
| FDA Compliance | Since these are "medical/nursing" products, ensure they are not making drug claims (e.g., "Cures Fever"). Use terms like "Relieves discomfort" or "Physical cooling." |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3005.10.10.00 etc. |
10.0% (Section 122) | FDA (if medical claim) | Highest scrutiny on "medicated" content. |
| π¨π³ China | 3005.10.10.00 |
0-5% | NMPA (if medical device) | Low tariff, high regulatory barrier. |
| πͺπΊ EU | 3005.90.90 |
0% | CE (Medical Device Regulation) | Requires MDR/IVDR compliance for medical claims. |
| π¬π§ UK | 3005.90.90 |
0% | UKCA | Similar to EU. |
| π―π΅ Japan | 3005.90.90 |
0-10% | PMDA/Quasi-drug | Classify as "Quasi-drug" if containing menthol. |
π Conclusion:
- USA imposes a flat 10% additional tariff on these medical dressings from China.
- Compliance is key: Misdeclaring a medicated patch as a "cosmetic" or "physical cooler" can lead to seizure or heavy fines.
π VI. Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring as "Cosmetic Face Mask"
π Consequence: FDA seizure if it contains medicinal ingredients (e.g., menthol, camphor). Cosmetics cannot claim therapeutic effects.
β Mistake 2: Ignoring Section 122 Tariff
π Consequence: Underpayment of duties. Customs will assess 10% back-tariff + interest + penalties.
β Mistake 3: Claiming "De Minimis" Exemption for Section 122 Goods
π Consequence: Packages held in transit. Customs may require formal entry (CBP Form 7501) anyway, delaying delivery.
β Mistake 4: Vague Description: "Cooling Patch"
π Consequence: Customs examiner assigns random code, potentially leading to incorrect duty assessment or audit flag.
β Correct Approach:
"Cold Compress Patches, Adhesive Back, Containing Menthol & Water, Medical/Nursing Use, HS Code 3005.10.10.00, Made in China."
π― VII. Conclusion: Professional Declaration for Smooth Customs Clearance
π― Remember the Mantra:
πΉ "Medicated = Chapter 30"
πΉ "Adhesive + Cooling Agent = 3005.10/90"
πΉ "Section 122 = +10% Tariff"
πΉ "Don't De Minimis, Declare Full!"
π Pro Tip:
If your product is 100% physical (no chemicals, no drugs, just water/gel in a plastic pouch), it might qualify for a different HS Code (e.g., 3926 or 5911) with potentially lower duties, but you must prove zero medicated content. For most commercial "cold patches," 3005 is the safe and correct classification.
π Action Item:
π Contact your customs broker with Ingredient List + Product Photos.
π Verify HS Code before shipment to avoid 10% surprise duties!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Save Costs, Avoid Delays, Stay Compliant!
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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.