Flame Retardant Leather
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3921121100 | 39.2% | CN | US | Official Doc |
| 3921131500 | 41.5% | CN | US | Official Doc |
| 4202316000 | 43.0% | CN | US | Official Doc |
| 3506915000 | 37.1% | CN | US | Official Doc |
| 4002190019 | 35.0% | CN | US | Official Doc |
Product Images
AI Analysis
π₯ Flame Retardant Leather: HS Code Classification & US Customs Clearance Guide (2026)
π HS Code Reference & Clearance Strategy | 2026 Latest Tariff Analysis | Professional-Level Compliance
π I. Product Definition & Classification: What is "Flame Retardant Leather"?
Flame Retardant Leather is not a single monolithic product. In international trade, its classification depends entirely on the base material (PVC, PU, Rubber) and the form/usage (composite sheet vs. finished article). The "flame retardant" property is a performance characteristic, not a primary classification driver under the Harmonized System (HS), unless it dictates the fundamental nature of the good.
β οΈ Critical Distinction: - If it is a sheet/film made of PVC or PU: It falls under Chapter 39 (Plastics). - If it is a finished article (e.g., a handbag) made of leather-like material: It falls under Chapter 42 (Articles of Leather). - If it is Synthetic Rubber: It falls under Chapter 40 (Rubber). - If it is an Adhesive containing synthetic rubber: It falls under Chapter 35.
π¦ II. HS Code Classification Details (2026 Latest Tariff Concordance)
| HS Code | Product Description & Logic | Application Scenario | Base Material |
|---|---|---|---|
3921.12.11.00 |
Flame Retardant Leather as PVC Composite: PVC coated on fabric base. Fits "Plastics" chapter. | Synthetic leather sheets, PVC-based upholstery, automotive interiors | PVC |
3921.13.15.00 |
Flame Retardant Leather as PU Composite: PU coating on substrate. Fits "Plastics" chapter (sheets/films). | PU-based faux leather, flexible packaging, consumer goods | PU |
4202.31.60.00 |
Flame Retardant Leather as Finished Article: Fits "ε εΊ" (catch-all) for containers like handbags. | Handbags, briefcases, wallets made from flame-retardant leather-like material | Leather-like |
3506.91.50.00 |
Flame Retardant Synthetic Rubber Adhesive: Based on polymers from headings 39.01-39.13. | Industrial adhesives/sealants containing synthetic rubber | Synthetic Rubber (Adhesive) |
4002.19.00.19 |
Flame Retardant Synthetic Rubber: Named synthetic rubber, flame retardant is a performance feature. | Raw synthetic rubber compounds, functional rubber products | Synthetic Rubber |
π Key Reminder: - PVC & PU variants are classified as Plastics (Chapter 39) because they are composite sheets/films, not actual animal leather. - Rubber variants are classified under Chapter 40 (if raw/compound) or Chapter 35 (if adhesive). - Finished Goods (like bags) jump to Chapter 42, regardless of the plastic/rubber nature of the material, if they meet the definition of an "article of leather."
π° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
β Applicable Country: USA (US) β Origin: China (CN) β Effective Time: Current as of 2026 β οΈ Note: All rates below include Base Tariff + Section 301 Tariff (25%) + Section 122 Tariff (10%).
π― 1. 3921.12.11.00 β PVC-Based Flame Retardant Leather (Composite)
| Item | Detail |
|---|---|
| Base Tariff | 4.2% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Effective Rate | 39.2% |
| Tax Calculation | CIF Value Γ 39.2% |
| De Minimis Exemption? | β NO (Section 301 goods are excluded from de minimis relief) |
| Legal Basis Path | USITC:3921.12.11.00 β FOOTNOTE:301 β SECTION122:10% |
π Explanation: - PVC-based synthetic leather is heavily scrutinized due to its plastic nature. - The 39.2% rate is high, impacting margin significantly for textile-composite imports.
π― 2. 3921.13.15.00 β PU-Based Flame Retardant Leather (Composite)
| Item | Detail |
|---|---|
| Base Tariff | 6.5% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Effective Rate | 41.5% |
| Tax Calculation | CIF Value Γ 41.5% |
| De Minimis Exemption? | β NO |
| Legal Basis Path | USITC:3921.13.15.00 β FOOTNOTE:301 β SECTION122:10% |
π Explanation: - PU-based composites often face a slightly higher base tariff than PVC. - This is the most common classification for high-end "faux leather" used in fashion and interiors.
π― 3. 4202.31.60.00 β Finished Flame Retardant Leather Articles (e.g., Handbags)
| Item | Detail |
|---|---|
| Base Tariff | 8.0% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Effective Rate | 43.0% |
| Tax Calculation | CIF Value Γ 43.0% |
| De Minimis Exemption? | β NO |
| Legal Basis Path | USITC:4202.31.60.00 β FOOTNOTE:301 β SECTION122:10% |
π Explanation: - Even if the material is synthetic, if it is made into a bag, it is classified as "Articles of Leather" (Chapter 42). - This category has the highest total rate (43.0%) among the material sheets due to the higher base tariff for finished goods.
π― 4. 3506.91.50.00 β Flame Retardant Synthetic Rubber Adhesive
| Item | Detail |
|---|---|
| Base Tariff | 2.1% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Effective Rate | 37.1% |
| Tax Calculation | CIF Value Γ 37.1% |
| De Minimis Exemption? | β NO |
| Legal Basis Path | USITC:3506.91.50.00 β FOOTNOTE:301 β SECTION122:10% |
π Explanation: - If the product is an adhesive containing synthetic rubber, it is classified here. - Lower base tariff makes this slightly more competitive than PVC/PU sheets, but the 35%+ total remains a significant cost.
π― 5. 4002.19.00.19 β Flame Retardant Synthetic Rubber (Raw/Functional)
| Item | Detail |
|---|---|
| Base Tariff | 0.0% |
| Section 301 Surcharge | +25.0% |
| Section 122 Surcharge | +10.0% |
| Total Effective Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35.0% |
| De Minimis Exemption? | β NO |
| Legal Basis Path | USITC:4002.19.00.19 β FOOTNOTE:301 β SECTION122:10% |
π Explanation: - This is the lowest total rate (35.0%) among all options. - Applicable only if the product is pure synthetic rubber (not coated on fabric, not an adhesive) and imported as raw/functional material. - "Flame retardant" is treated as a secondary feature.
π οΈ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)
β 1. Preparation Checklist (Mandatory)
| Document | Required | Purpose |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state base material (PVC/PU/Rubber) and "Flame Retardant" certification (e.g., UL94, CPAI-84). |
| β Material Safety Data Sheet (MSDS) | βοΈ | For rubber/adhesive products, to confirm chemical composition and origin. |
| β Product Photos (Clear Labels) | βοΈ | Show the texture, backing (fabric vs. raw), and any finished goods shapes (if Chapter 42). |
| β Third-Party Test Report | βοΈ | Proof of flame retardancy. Critical for defining the product as "functional" rather than general use. |
| β Commercial Invoice | βοΈ | Must explicitly describe the material (e.g., "PVC-Coated Fabric, Flame Retardant"). Vague terms like "Leather" without clarification can lead to misclassification. |
| β Packing List | βοΈ | Detailed weight and dimensions. |
β 2. Classification Strategy & Tips
π₯ βMaterial First, Form Second: PVC/PU is Plastic, Rubber is Rubber, Bags are Bags!β
| Scenario | Correct Classification | Common Error | Consequence |
|---|---|---|---|
| PVC Sheet on Fabric | 3921.12.11.00 |
Classify as "Textile" | Wrong Chapter, Penalty, Delay |
| PU Sheet on Fabric | 3921.13.15.00 |
Classify as "Leather" | Wrong Chapter, Penalty, Delay |
| Handbag made of PU | 4202.31.60.00 |
Classify as "PU Sheet" | Wrong Rate (41.5% vs 43.0% - similar, but wrong legal path) |
| Synthetic Rubber Compound | 4002.19.00.19 |
Classify as "Plastic" | Wrong Chapter, Penalty |
| Adhesive with Rubber | 3506.91.50.00 |
Classify as "Chemical" (General) | Wrong Subheading, Potential Audit |
β 3. Special Handling Instructions
| Situation | Recommendation |
|---|---|
| OEM Custom Materials | Provide customer design specs to prove it is a specific composite (e.g., PVC+Fabric) rather than a general chemical. |
| Flame Retardant Certification | Attach test reports (UL, ASTM, NFPA) to prove the "flame retardant" claim. This prevents Customs from reclassifying it as a standard (higher risk) plastic. |
| Mixed Shipments | If a shipment contains both sheets and finished bags, separate line items must be declared with distinct HS Codes. Do not lump them under one code. |
| Origin Declaration | Ensure the COO (Country of Origin) is declared as China. The 25% + 10% surcharges apply strictly to Chinese-origin goods. |
π V. Global Market Clearance Comparison (2026)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Key Certification | Note |
|---|---|---|---|---|
| πΊπΈ USA | 3921.12.11.00 / 4202.31.60.00 |
39.2% - 43.0% | UL, CPAI-84 | Highly taxed. Section 301 + 122 apply. |
| π¨π³ China | Same HS Codes | 0% - 8% (Import Duty) | CCC (if applicable) | Low entry barrier. |
| πͺπΊ EU | 39.21 or 42.02 | ~0% - 6% | REACH, RoHS | No US-style surcharges. |
| π¦πΊ Australia | Same HS Codes | ~5% | RCM | Moderate duty, no 301 surcharge. |
| π―π΅ Japan | Same HS Codes | ~0% - 8% | PSE | No surcharges. |
π Conclusion: - The USA is the most challenging market for Flame Retardant Leather due to theε ε (stacked) tariffs. - EU/Asia/Australia do not impose the 25% Section 301 or 10% Section 122 tariffs, making these markets significantly more cost-effective for Chinese manufacturers.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Mistake 1: Calling "PVC-Coated Fabric" simply "Leather" π Result: Customs may classify it as "Real Leather" (Chapter 41) or "Textiles" (Chapter 60), leading to misclassification penalties and delays. π Fix: Use precise terms: "Synthetic Leather (PVC-Coated)" or "PVC Composite Sheet."
β Mistake 2: Ignoring the "Flame Retardant" claim in documentation π Result: Customs may assume standard flammability standards, leading to rejection of safety-critical goods in regulated industries (automotive, aviation). π Fix: Include test reports and explicit "Flame Retardant" labels on the invoice.
β Mistake 3: Lumping Finished Goods with Raw Materials π Result: If you ship bags and sheets together under one HS Code, Customs will penalize for incorrect classification and potential duty evasion. π Fix: Separate line items in the Commercial Invoice and Packing List.
β Correct Declaration Example:
"Synthetic Leather Sheets, PVC-Coated Fabric Substrate, Flame Retardant Certified per UL94 V-0, HS Code 3921.12.11.00, Origin: China"
π― VII. Conclusion: Professional Classification, Cost Control, Compliance
π― Key Takeaways:
πΉ "PVC & PU are Plastics, Not Leather" β Classify under Chapter 39. πΉ "Finished Bags are Chapter 42" β Higher base tariff, but same surcharges. πΉ "Rubber is Chapter 40 or 35" β Lowest potential rate (35%) if raw. πΉ "USA Tariffs are Stacked" β Base + 25% + 10% = High Cost. Plan margins accordingly.
πΉ "HS Code Determines Your Duty, Not Just Your Name" πΉ "One Mistake in Material Description Can Cost You 25% Extra"
π Pro Tip: If your flame retardant leather products are not of Chinese origin (e.g., manufactured in Vietnam or Thailand), you may avoid the 25% Section 301 and 10% Section 122 tariffs. π Action: Consider supply chain diversification or Rule of Origin analysis to qualify for non-China origin status.
π£ Immediate Action:
π Consult with a Licensed Customs Broker to confirm the specific HS Code for your product's exact composition. π Secure Pre-Rulings from US Customs and Border Protection (CBP) if the classification is ambiguous. πΌ Optimize Your Invoice Descriptions to reflect the true nature of the good (PVC/PU/Rubber + Flame Retardant Feature).
β¨ Professional Clearance Starts with Accurate Classification! πΌ Your Profit Margin Depends on Your HS Code Choice!
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.