Fine Color Lotion
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3304910050 | 35.0% | CN | US | Official Doc |
| 3304995000 | 35.0% | CN | US | Official Doc |
| 3210000000 | 36.8% | CN | US | Official Doc |
| 3209100000 | 40.1% | CN | US | Official Doc |
| 3209900000 | 40.9% | CN | US | Official Doc |
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AI Analysis
𧴠Fine Color Lotion (彩θ²δΉ³ζΆ²)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π 1. Product Definition & Classification: What is "Fine Color Lotion"?
"Fine Color Lotion" is a versatile term that creates classification ambiguity in international trade. It sits at the intersection of cosmetics/skincare and paints/coatings, depending on its specific formulation, viscosity, and intended use.
- Cosmetic/Skincare Interpretation: If the "lotion" is for skin care (moisturizing, tinted skincare), it falls under Chapter 33.
- Paint/Coating Interpretation: If the "lotion" is a liquid pigment medium, acrylic dispersion, or artistic paint, it falls under Chapter 32.
β οΈ Key Distinction Point:
- If it is a skin-care product (e.g., tinted moisturizer, body lotion) β Chapter 33.
- If it is a paint/coating (e.g., acrylic paint, artistic color medium) β Chapter 32.
π¦ 2. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Tax Category |
|---|---|---|---|
3304.91.00.50 |
Beauty or Make-up Preparations and Preparations for the Care of the Skin (Other) | Skincare lotions, tinted moisturizers, "other" forms in powder/powder-like category | 35.0% |
3304.99.50.00 |
Other Beauty or Make-up Preparations and Preparations for the Care of the Skin | Liquid/Semi-liquid skincare lotions, non-specific cosmetic emulsions | 35.0% |
3210.00.00.00 |
Other Paints and Varnishes (including Enamels and Lacquers) | Colored liquid paints, artistic "lotion" paints, color-modifying coatings | 36.8% |
3209.10.00.00 |
Paints and Varnishes Based on Synthetic Polymers Dispersed in a Non-Aqueous Medium | Acrylic or vinyl polymer dispersions (water-based or non-aqueous) | 40.1% |
3209.90.00.00 |
Other Paints and Varnishes Based on Synthetic Polymers | Fine chemical modified emulsions, non-specified synthetic polymer colors | 40.9% |
π Key Reminder:
- Skincare Products generally fall under 3304. The distinction between3304.91(Powder/Other) and3304.99(Other/Liquid) depends on the physical state. "Lotion" usually implies liquid/semi-liquid, favoring3304.99, but some customs may interpret certain textured lotions as3304.91if they have powder-like dispersion properties.
- Paint/Art Materials fall under 3209/3210. If the product is a "color" in a liquid medium for artistic or industrial coating purposes, it is not a cosmetic, even if it looks like lotion.
π° 3. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (including subsequent imports)
π― 1. 3304.91.00.50 & 3304.99.50.00 ββ Cosmetics & Skincare Lotions
| Item | Content |
|---|---|
| Base Duty Rate | 0.0% (ad valorem) |
| USITC Surcharge | +25.0% (Under Section 301 / USITC Footnote) |
| IEEPA Surcharge | +10.0% (Against China/HK Products, effective Nov 10, 2025) |
| Total Tax Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Exemption | β Not Applicable (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3304.91/99 β FOOTNOTE:3304 |
π Explanation:
- "Base 0%": Cosmetics generally have low base tariffs.
- "25% Surcharge": From the US Trade Act Section 301 investigation on Chinese goods.
- "10% IEEPA Surcharge": From the International Emergency Economic Powers Act, targeting specific Chinese imports.
- Total 35%: This is a high tariff for cosmetics. You must plan for this cost.
π― 2. 3210.00.00.00 ββ Other Paints and Varnishes (Colored Lotion)
| Item | Content |
|---|---|
| Base Duty Rate | 1.8% |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tax Rate | 36.8% |
| Tax Calculation | CIF Value Γ 36.8% |
| De Minimis Exemption | β Not Applicable (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3210 β FOOTNOTE:3210 |
π Note:
- If the "Fine Color Lotion" is classified as a paint (e.g., acrylic art paint), the base rate is 1.8%, not 0%.
- However, the surcharges remain the same, leading to a slightly higher total (36.8%).
π― 3. 3209.10.00.00 & 3209.90.00.00 ββ Synthetic Polymer Paints/Coatings
| Item | Content |
|---|---|
| Base Duty Rate | 5.1% (for 3209.10) / 5.9% (for 3209.90) |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10.0% |
| Total Tax Rate | 40.1% (for 3209.10) / 40.9% (for 3209.90) |
| Tax Calculation | CIF Value Γ 40.1% / 40.9% |
| De Minimis Exemption | β Not Applicable (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:3209 β FOOTNOTE:3209 |
π Warning:
- These classifications apply if the lotion is a technical chemical product (e.g., industrial coating, polymer dispersion).
- Total rates exceed 40%. This is the highest tax bracket among the options. Avoid this classification unless the product is strictly an industrial material.
π οΈ 4. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)
β 1. Preparation Checklist (Non-negotiable)
| Document | Required | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must state: Physical state (liquid/powder), Ingredients (Cosmetic vs. Paint), Intended Use (Skin vs. Surface). |
| β Product Photos (Labeled) | βοΈ | Clear images of the container, label, and texture. |
| β Safety Data Sheet (SDS) | βοΈ | Critical for distinguishing between Cosmetic (Chapter 33) and Chemical/Paint (Chapter 32). |
| β Commercial Invoice | βοΈ | Must use precise terminology (e.g., "Tinted Skin Care Lotion" vs. "Acrylic Color Medium"). |
| β Certificate of Origin (CO) | βοΈ | If not China-origin, check for FTZ benefits. |
| β Packaging List | βοΈ | Show packing details to avoidζεη³ζ₯ (split declaration). |
β 2. Declaration Strategy (Key Mnemonics)
π₯ "Skincare is 35%, Paint is 40%, Don't Guess, Just Classify!"
| Scenario | Correct HS Code | Wrong Way | Consequence |
|---|---|---|---|
| Tinted Moisturizer (for face/body) | 3304.99.50.00 (35.0%) |
Misclassify as Paint | Unjustified higher tax or audit. |
| Artistic Acrylic Paint (liquid) | 3210.00.00.00 (36.8%) or 3209.10.00.00 (40.1%) |
Misclassify as Cosmetic | Risk of penalty for misdeclaration. |
| Powder Foundation/Compact | 3304.91.00.50 (35.0%) |
Misclassify as Liquid | Classification error. |
| Industrial Color Coating | 3209.90.00.00 (40.9%) |
Misclassify as Cosmetic | High tax avoidance suspicion. |
β 3. Special Cases Handling
| Situation | Handling Advice |
|---|---|
| "Color" in Name | Does "Fine Color" mean "Tinted Cosmetic" or "Pigmented Paint"? Check the INCI list (Cosmetic) vs. Resin/Pigment content (Paint). |
| Liquid "Lotion" Texture | If it is for painting, use Chapter 32. If for skin, use Chapter 33. Texture alone does not determine classification. |
| OEM/Private Label | Provide the brand owner's specifications to prove intended use (e.g., "For Cosmetic Use Only"). |
| Small Sample Shipments | Even small values are subject to full tariff (no de minimis exemption for China). Plan for 35-40% cost. |
π 5. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification Requirement | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3304.99.50.00 (Cosmetic) |
35.0% | FDA Registration (Voluntary but recommended) | High surcharges (25%+10%). |
| πΊπΈ USA | 3210.00.00.00 (Paint) |
36.8% | CLP/Prop 65 | Slightly higher base rate. |
| π¨π³ China | 3304.99.50.00 |
5.0% | NMPA/FDA | No surcharges. |
| πͺπΊ EU | 3304.99 |
6.5% | CPNP Notification | No Section 301 tariffs. |
| π―π΅ Japan | 3304.99 |
8.9% | Quasi-drug/Cosmetic Filing | No surcharges. |
π Conclusion:
- USA is the most expensive market due to the 35-41% total tariff burden.
- Accuracy is critical: Misclassifying a cosmetic as a paint (or vice versa) can lead to audits, penalties, or seized goods.
- Cost Planning: Factor in 35-41% of CIF value for US imports from China.
π 6. Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Using "Lotion" and assuming it's always 3304 (Cosmetic).
π Consequence: If it's an acrylic art paint, customs will reclassify to 3209 (40.1%) + penalties.
β Error 2: Ignoring the "Color" aspect.
π Consequence: If the product is a "Colorant" for industrial use, it may fall under 3209 (40.9%), not 3304 (35.0%).
β Error 3: Assuming De Minimis (Section 321) applies.
π Consequence: No de minimis exemption for China-origin goods under current IEEPA rules. Every dollar is taxed.
β Correct Approach:
"Define Use First, Then Classification."
- Is it for Skin? β 3304 (35.0%)
- Is it for Surface/Painting? β 3209/3210 (36.8%-40.9%)
- Document the Intent with SDS and Product Specs.
π― 7. Conclusion: Precise Classification, Efficient Clearance!
π― Remember the Mnemonic:
πΉ "Skin is 35, Paint is 40, Check the Use, Save Your Budget!"
πΉ "No De Minimis for China, Plan Your Tax, Avoid the Stress!"
π Pro Tip:
If your product is a hybrid (e.g., "Color-Correcting Skin Cream"), stick to 3304 if the primary function is skincare. Provide clinical or cosmetic testing reports to support the "skincare" classification.
π£ Immediate Action:
π Contact a Professional Customs Broker
π Prepare SDS + Product Specs
π Apply for an Advance Ruling (if possible)
πΌ Ensure Your "Fine Color Lotion" Clears Smoothly and Profitably!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Percent Matters in the 2026 Tariff Landscape!
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.