📦 Faux Leather Powder Compact: HS Code Classification & Duty Breakdown (2026)

🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy

📌 I. Product Definition & Classification: What Exactly is a "Faux Leather Powder Compact"?

A Faux Leather Powder Compact is a portable cosmetic case used for storing pressed powder, foundation, or blush. Unlike rigid metal or plastic cases, it is characterized by its outer shell material (imitation leather/Vegan leather) which often mimics the texture and appearance of genuine leather but is made from synthetic materials such as PVC, PU, or other polymers.

Key Classification Dilemma:
The core challenge in customs clearance lies in determining whether the item is classified primarily as: 1. A Plastic Article (if the structure/material is deemed predominantly plastic/synthetic resin). 2. A Metal/Steel Article (if the internal frame/structure is metal and the outer layer is just a coating/fabric). 3. A Decorative/Accessory Item (depending on the specific construction and primary function).

⚠️ Critical Distinction Point:
- If the compact is mostly plastic/synthetic resin in nature (even with leather-like finish) → It often falls under Chapter 39 (Plastics).
- If the compact has a metal core/structure with a decorative outer layer → It may be classified under Chapter 73 (Iron/Steel) or Chapter 83 (Miscellaneous Articles of Base Metal).
- Do not assume it is "Gold/Silver" or "Precious Metal" unless specified. Most faux leather compacts are base materials.

📦 II. Detailed HS Code Breakdown (Based on Provided Data)

According to the provided data, the following HS Codes have been identified for "Faux Leather Powder Compact" items. Note that the classification varies significantly based on the primary material and structure inferred by customs authorities.

🔍 Key Insight:
- Plastic-based classifications (39xx) generally result in significantly lower tariffs (15.3% - 38.5%) compared to Metal/Steel-based classifications (73xx/83xx) (87.7% - 92.8%).
- This is due to the application of Section 301 tariffs and 122 Clauses which heavily penalize steel/aluminum/copper products from China.

💰 III. 2026 Tariff Rate Detailed Explanation

✅ Applicable Country: United States (US)
✅ Origin: China (CN)
✅ Effective Date: 2025/2026 (Based on current trade policies)

🎯 1. High-Tariff Scenarios: Metal/Steel Based (HS 7326 & 8306)

These codes trigger the maximum punitive tariffs due to the "122 Clause" and Section 301 duties.

Case A: HS 7326.90.35.00 (Steel Container)

• Base Duty: 7.8%
• Section 301 Tariff (Additional): 25.0%
• 122 Clause Tariff (Steel/Aluminum/Copper): 50.0%
• Total Tax: 92.8%
• Calculation: CIF Value × 92.8%
• Legal Basis: Steel/Aluminum/Copper products face an additional 50% under the 122 Clause,叠加 on top of the 25% Section 301 duty and the base duty.

Case B: HS 8306.30.00.00 (Base Metal Decorative)

• Base Duty: 2.7%
• Section 301 Tariff (Additional): 25.0%
• 122 Clause Tariff (Steel/Aluminum/Copper): 50.0%
• Total Tax: 87.7%
• Calculation: CIF Value × 87.7%
• Note: Even though it’s a "decorative" item, if deemed base metal, it suffers the same heavy penalties.

Case C: HS 7326.90.86.88 (Other Steel/Plastic Mix)

• Base Duty: 2.9%
• Section 301 Tariff (Additional): 25.0%
• 122 Clause Tariff (Steel/Aluminum/Copper): 50.0%
• Total Tax: 87.9%
• Calculation: CIF Value × 87.9%
• Reasoning: Despite the "plastic or metal" inference, if classified under Chapter 73, the 122 Clause steel penalty applies.

🎯 2. Low-Tariff Scenarios: Plastic Based (HS 3926)

These codes are highly recommended if the product can be substantiated as primarily plastic/synthetic.

Case D: HS 3926.90.45.10 (Plastic Finished Article)

• Base Duty: 3.5%
• Section 301 Tariff (Additional): 25.0%
• 122 Clause Tariff: None (Plastics are not subject to the 50% steel/aluminum penalty)
• Total Tax: 38.5%
• Calculation: CIF Value × 38.5%
• Advantage: Significantly lower than metal classifications.

Case E: HS 3926.40.00.90 (Plastic Ornament/Daily Use)

• Base Duty: 5.3%
• Section 301 Tariff (Additional): 0.0% (Note: This specific subheading may be excluded from the 25% list or has a zero rate applied in this dataset)
• 122 Clause Tariff: None
• Total Tax: 15.3%
• Calculation: CIF Value × 15.3%
• Advantage: Lowest possible tax rate. This is the optimal classification if the product fits the description of a "plastic ornament" or "daily use plastic article" without triggering Section 301.

📌 Explanation of Tariffs:
- Base Duty: The standard MFN (Most Favored Nation) rate.
- Section 301 Tariff (25% or 0%): Applied to Chinese goods under Trade Act Section 301. Some plastic subheadings may have different treatment.
- 122 Clause Tariff (50%): Applied specifically to Steel, Aluminum, and Copper products. Plastics are NOT subject to this.
- Total Tax: Sum of Base + Section 301 + 122 Clause.

🛠️ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)

✅ 1. Preparation Checklist (Must-Haves)

✅ 2. Declaration Strategy (Key Mantra)

🔥 "Declare as Plastic, Not Metal! Provoke Synthetic, Not Steel!"

Actionable Advice: 1. Prioritize HS 3926.40.00.90 if the product is purely plastic/synthetic with no metal structural frame. This offers the 15.3% rate. 2. Use HS 3926.90.45.10 if it’s a general plastic cosmetic case, resulting in 38.5%. 3. Avoid HS 73xx/83xx unless the compact has a significant metal structure (e.g., hinges, frame) that dictates its essential character. If you use these, expect ~88-93% tax.

✅ 3. Special Considerations

🌍 V. Global Market Comparison (2026)

📌 Conclusion for US Market:
The 122 Clause is the biggest threat. By classifying the "Faux Leather Compact" as a Plastic Product (Chapter 39) rather than a Steel/Base Metal Product (Chapter 73/83), you save ~50% in additional tariffs.
- Metal Classification: ~90% Tax
- Plastic Classification: ~15-38% Tax
Savings: ~50-75% on duty costs!

📌 VI. Common Mistakes & Pitfalls (Lessons Learned)

❌ Mistake 1: Declaring "Leather Compact" without specifying "Faux/Synthetic."
👉 Consequence: Customs may classify it as genuine leather (Chapter 42) or reject it if documentation is missing, or misclassify as metal if texture looks metallic.
👉 Fix: Always declare "Synthetic Leather (PU/PVC)."

❌ Mistake 2: Using HS 7326.90.35.00 for a plastic compact.
👉 Consequence: Paying 92.8% tax instead of 15.3%.
👉 Fix: Verify material composition. If >50% by weight/value is plastic/synthetic, use Chapter 39.

❌ Mistake 3: Ignoring the 122 Clause.
👉 Consequence: Unexpected 50% additional tax on steel-based items.
👉 Fix: Avoid any classification under Chapter 73, 72, 74, 76 unless absolutely necessary.

🎯 VII. Conclusion: Optimize Clearance, Minimize Tax

🎯 Remember the Mantra:

🔹 "Plastic is King, Steel is Heavy!"
🔹 "Faux Leather = Synthetic = Plastic (3926), NOT Steel (7326)."
🔹 "Save 50% by choosing 3926.40.00.90 (15.3% Tax)!"

📌 Pro Tip:
If your product is shipped from Vietnam, Mexico, or Malaysia, it may be eligible for IEEPA Exemptions or lower Section 301 rates.
For US-bound shipments from China, always prioritize HS Code 3926.40.00.90 or 3926.90.45.10 to avoid the punitive 122 Clause steel tariffs.

📣 Immediate Action Required:

📞 Consult your customs broker with material composition sheets.
📄 Ensure your invoice reads: "Cosmetic Case, Synthetic Leather, Plastic Interior."
🚀 Classify under HS 3926 to save up to 75% in duties!

✨ Professional clearance starts with accurate classification!
💼 Every percentage point of tax saved is pure profit!