Facial Cleansing Towel
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3926909950 | 22.8% | CN | US | Official Doc |
| 4818200040 | 35.0% | CN | US | Official Doc |
| 5603110070 | 35.0% | CN | US | Official Doc |
| 5603910090 | 35.0% | CN | US | Official Doc |
| 4818200020 | 35.0% | CN | US | Official Doc |
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AI Analysis
π§ββοΈ Facial Cleansing Towel (Facial Cleansing Tissue)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "Facial Cleansing Towels"?
Facial cleansing towels are personal care products used for cleaning the face. In international trade, they are classified based on material composition (Paper vs. Non-woven Fabric) and use case (Cosmetic/Hygiene vs. Medical/Sanitation). Because the term "towel" can refer to both paper tissues and non-woven fabrics, the HS Code classification diverges significantly, impacting duty rates and compliance requirements.
β οΈ Critical Distinction Point:
- If the product is made of wood pulp/cellulose (soft, absorbent paper texture) β It is classified as Paper Tissues (Chapter 48).
- If the product is made of synthetic fibers (non-woven fabric, often polyester or viscose, durable, washable or disposable textile-like) β It is classified as Non-woven Products (Chapter 56).
- If the product is specifically disposable wet wipes for disinfection/medical use β It falls under Plastic/Composite Sanitary Articles (Chapter 39).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Key Characteristics | Material Basis |
|---|---|---|---|
4818.20.00.20 |
Facial paper, tissues, towels | Purely paper-based, soft, high absorption | Paper/Cotton Pulp |
4818.20.00.40 |
Handkerchiefs, cleaning cloths, facial tissues | Paper-based, for general cleaning/facial use | Paper/Cellulose |
5603.11.00.70 |
Non-woven fabrics, impregnated or coated (Lightweight) | Synthetic fiber non-woven, often pre-moistened | Synthetic Fibers |
5603.91.00.90 |
Other non-woven fabrics (Lightweight, < 25 g/mΒ²) | Thin non-woven fabric, not rubber/plastic/wood pulp soaked | Synthetic/Artificial Fibers |
3926.90.99.50 |
Sanitary/Hygiene Articles of Plastic (Disinfectant Wipes) | Disinfectant wipes, medical/hygiene plastic composites | Plastic/Fiber Composite |
π Key Reminder:
- Paper vs. Non-woven: The physical feel is key. Paper tears easily when wet; Non-woven is more durable.
- Disinfection Claim: If the product claims "disinfectant" or "antibacterial" functionality and is packed as a medical/hygiene item, Customs may lean toward 3926.90.99.50, which carries a different tax structure.
- Weight Matters: Non-woven codes (5603.11.00.70/5603.91.00.90) typically apply to lightweight fabrics (< 25 g/mΒ²).
π° III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: From November 10, 2025 (for subsequent imports)
π― 1. Paper-Based Classifications: 4818.20.00.20 & 4818.20.00.40
These codes cover traditional facial tissues and paper cleaning cloths.
| Item | Content |
|---|---|
| Base Tariff Rate | 0% (ad valorem) |
| Section 301 Surtax | +25% (Under USITC Footnote 9903.88.01) |
| IEEPA Surtax | +10% (Targeting China/HK products, effective Nov 10, 2025) |
| Total Effective Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:4818.20.00.20/40 β FOOTNOTE:9903.88.01 |
π Explanation:
- Although the base tariff is 0%, the Section 301 (25%) + IEEPA (10%) surcharges bring the total to 35%.
- These goods are subject to high tariffs due to their origin (China).
- No de minimis exemption applies, meaning even small parcels are fully taxed.
π― 2. Non-Woven Fabric Classifications: 5603.11.00.70 & 5603.91.00.90
These codes cover non-woven fabric facial towels, often made of synthetic fibers.
| Item | Content |
|---|---|
| Base Tariff Rate | 0% (ad valorem) |
| Section 301 Surtax | +25% (Under USITC Footnote 9903.88.01) |
| IEEPA Surtax | +10% (Targeting China/HK products, effective Nov 10, 2025) |
| Total Effective Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9901.25 β IEEPA:9903.01.24 β USITC:5603.11.00.70/5603.91.00.90 β FOOTNOTE:9903.88.01 |
π Note:
- Similar to paper tissues, the base rate is 0%, but the surcharge totals 35%.
- Both lightweight non-woven codes face identical tariff structures under current US-China trade policies.
- "Lightweight" (typically < 25 g/mΒ²) is a critical descriptor to ensure correct classification.
π― 3. Medical/Hygiene Plastic Class: 3926.90.99.50
This code applies if the product is classified as a disinfectant wipe or hygiene article made of plastic/fiber composite.
| Item | Content |
|---|---|
| Base Tariff Rate | 5.3% (ad valorem) |
| Section 301 Surtax | +7.5% (Under USITC Footnote 9903.88.01) |
| 122 Clause Surtax | +10% (Specific Clause 122 Tariff) |
| Total Effective Rate | 22.8% |
| Tax Calculation | CIF Value Γ 22.8% |
| De Minimis Eligibility | β Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3926.90.99.50 β CLAUSE:122 |
π Explanation:
- This code has a higher base tariff (5.3%) but lower surcharges (7.5% + 10%), resulting in a lower total rate of 22.8% compared to paper/non-woven (35%).
- Strategic Advantage: If your product can be legitimately classified as a disinfectant/hygiene article (e.g., labeled as "antibacterial," "medical-grade," or "sanitary wipe") rather than just a "facial tissue," you may save 12.2% in duties.
- Requirement: Must meet the usage logic of "disinfectant/hygiene wipes" and not be purely for cosmetic cleansing.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Preparation Checklist (Required Documents)
| Document | Mandatory? | Description |
|---|---|---|
| β Product Spec Sheet | βοΈ | Must detail material (Paper vs. Non-woven), weight (g/mΒ²), and composition. |
| β Product Photos | βοΈ | Clear images showing texture, packaging, and labeling (especially "Disinfectant" claims if applicable). |
| β Bill of Lading / Commercial Invoice | βοΈ | Must accurately describe goods as "Facial Cleansing Towel" or "Non-woven Wipes," not just "Textiles." |
| β Certificate of Origin (CO) | βοΈ | Essential for proving China origin (and thus applicable surtaxes). |
| β Third-Party Test Report | βοΈ | If claiming "Disinfectant" or "Antibacterial," provide lab results to support 3926.90.99.50 classification. |
| β Packing List | βοΈ | Specify net/gross weight, number of pieces, and package dimensions. |
β 2. Declaration Tips (Critical Mantra)
π₯ βMaterial Defines Code, Claim Defines Tax! Paper=35%, Non-woven=35%, Disinfectant=22.8%!β
| Scenario | Correct Declaration | Incorrect Action |
|---|---|---|
| Paper Facial Tissues | 4818.20.00.20 or 4818.20.00.40 |
Declare as "Fabric" β Misclassification penalty |
| Non-woven Facial Towels | 5603.11.00.70 or 5603.91.00.90 |
Declare as "Paper" β Delay for inspection |
| Disinfectant Wipes | 3926.90.99.50 |
Declare as "Facial Tissue" β Overpay 12.2% duties |
| Mixed Paper & Non-woven | Split Declaration | Bundle together β High risk of audit/rejection |
β 3. Special Cases Handling
| Case | Handling Advice |
|---|---|
| OEM Private Label | Ensure the label clearly states material (e.g., "100% Polyester Non-woven") to avoid ambiguity. |
| "Wet" vs. "Dry" | If "Wet," ensure packaging is sealed. Wet wipes often fall under Chapter 39 or 56 depending on backing material. |
| Medical Grade Claim | If claiming medical/disinfectant use, provide FDA clearance or equivalent test reports to justify 3926.90.99.50. |
| Lightweight Non-woven | Ensure weight is < 25 g/mΒ². If heavier, it may fall under different subheadings with different tariffs. |
π V. Global Market Comparison for Facial Cleansing Towels (2026 Latest)
| Country/Region | Recommended HS Code | Duty Rate (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 4818.20.00.20 / 5603.11.00.70 / 3926.90.99.50 |
35% (Paper/Non-woven) 22.8% (Disinfectant) |
FCC (if electronic), RoHS (if applicable) | High surtaxes apply; strategic classification crucial. |
| π¨π³ China | 4818.20.00.20 / 5603.11.00.70 |
5% (Standard) | CCC (if applicable) | Lower base rates; no Section 301/IEEPA. |
| πͺπΊ EU | 4818.20 / 5603.11 |
4% - 6% | CE (if medical), REACH | No US-style surtaxes; VAT applies. |
| π¬π§ UK | 4818.20 / 5603.11 |
4% - 6% | UKCA | Post-Brexit standards apply. |
| π―π΅ Japan | 4818.20 / 5603.11 |
3% - 8% | PSE (if applicable) | No major surtaxes. |
π Conclusion:
- USA is the most tariff-sensitive market due to Section 301 and IEEPA surtaxes.
- Strategic Classification can save up to 12.2% in duties if the product qualifies as a disinfectant/hygiene article (3926.90.99.50).
- China and EU offer more stable, lower tariff environments.
π VI. Common Errors & Pitfall Avoidance (Lessons Learned)
β Error 1: Declaring "Non-woven Facial Towels" as "Paper Tissues"
π Consequence: Customs inspection reveals synthetic material β Delay, fines, or re-classification.
β Error 2: Declaring "Facial Towels" as "Clothing" (Chapter 61/62)
π Consequence: Wrong chapter β Denial of entry or high penalties.
β Error 3: Ignoring the "Disinfectant" Claim Opportunity
π Consequence: Paying 35% when you could pay 22.8% by correctly classifying as 3926.90.99.50 β Lost profit.
β Error 4: Failing to Specify Weight for Non-woven
π Consequence: If weight > 25 g/mΒ², 5603.11.00.70 may be invalid β Incorrect tariff application.
β Correct Approach:
"Facial Cleansing Towel, Non-woven, Polyester, 20g/mΒ², Pack of 50, Dry/Wet"
π― VII. Conclusion: Precision in Classification Saves Money!
π― Remember the Mantra:
πΉ "Paper=35%, Non-woven=35%, Disinfectant=22.8%. Choose Wisely!"
πΉ "HS Code is King, Surtax is Queen. Declaring Wrong is Pain!"
πΉ "Material Matters: Paper vs. Fiber. Claim Matters: Cosmetic vs. Medical."
π Pro Tip:
If your product is manufactured in Vietnam, Thailand, or Malaysia, you may be eligible for IEEPA Exemptions or lower tariffs under trade agreements.
Recommend applying for an Advance Ruling (Pre-classification) from US Customs and Border Protection (CBP) to lock in the correct HS Code and avoid post-entry audits.
π£ Take Action Now:
π Consult a Professional Broker + Provide Product Specs + Request HS Code Advance Ruling
π Ensure Smooth Customs Clearance, Efficient Export, and Maximized Profit!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Dollar of 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.