HCFC containing refrigerant formula
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3824995000 | 41.5% | CN | US | Official Doc |
| 2903710100 | 38.7% | CN | US | Official Doc |
| 2903750100 | 38.7% | CN | US | Official Doc |
| 3811190000 | 41.5% | CN | US | Official Doc |
| 3811900000 | 41.5% | CN | US | Official Doc |
AI Analysis
π§ͺ HCFC Refrigerant Formulas: HS Code Classification & Tariff Breakdown (US Imports from China)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
π I. Product Definition: What Exactly Are HCFC Refrigerants?
Hydrochlorofluorocarbons (HCFCs) are a group of halogenated hydrocarbons widely used as refrigerants, blowing agents, and solvents. They are transitional substances being phased out under the Montreal Protocol due to their ozone-depleting potential.
In international trade, HCFCs are classified primarily under two chapters: - Chapter 29: Halogenated derivatives of acyclic hydrocarbons (pure chemical compounds). - Chapter 38: Mixed chemical products, preparations, and anti-knock agents (formulas/mixtures).
β οΈ Critical Distinction:
- If the product is a pure, single-compound HCFC (e.g., R-22, R-141b) β Likely Chapter 29 (2903).
- If the product is a mixture, formula, or contains additives (even without CFCs) β Likely Chapter 38 (3811or3824).
π¦ II. HS Code Classification Details (Based on Provided Data)
The following analysis strictly adheres to the provided <DATA> context. Each HS Code is explained based on the chemical nature and tariff implications.
| HS Code | Summary from Data | Key Chemical Characteristic | Total Tax Rate |
|---|---|---|---|
| 2903.71.01.00 | "HCFC refrigerants belong to halogenated derivatives of non-cyclic hydrocarbons containing two or more different halogens." | Pure HCFC compound with mixed halogens (Cl, F, etc.). | 38.7% |
| 2903.75.01.00 | "HCFCs containing hydrogen, chlorine, and fluorine fit the characteristics of halogenated derivatives of hydrocarbons..." | Another specific sub-category for mixed-halogen HCFC derivatives. | 38.7% |
| 3811.19.00.00 | "HCFC refrigerants without CFCs belong to chemical preparations, fitting the liquid chemical substance attributes of anti-knock agents/additives." | Treated as a chemical preparation/additive, not a pure compound. | 41.5% |
| 3811.90.00.00 | "HCFC refrigerants without CFCs belong to chemical products, fitting the purpose logic of mixtures for mineral oils or similar liquids." | Classified under "Other mixtures/preparations" for liquid chemicals. | 41.5% |
| 3824.99.50.00 | "HCFC refrigerant compounds are halogenated hydrocarbons, highly consistent with halogenated hydrocarbon mixtures and chlorination characteristics." | Treated as a general mixture of halogenated hydrocarbons. | 41.5% |
π Key Takeaway:
- Pure Compounds (2903): Tax rate 38.7%. Applies when the product is a distinct chemical entity.
- Mixtures/Preparations (3811/3824): Tax rate 41.5%. Applies when the product is a blend, formula, or treated as a chemical preparation.
π° III. 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: Current surcharges apply (Base + Section 301 + 122 Clause)
π― 1. Chapter 29 Codes: 2903.71.01.00 & 2903.75.01.00
(For pure HCFC chemical compounds)
| Item | Content |
|---|---|
| Base Tariff | 3.7% |
| Section 301 Surtax | +25.0% (25% additional duty on Chinese goods) |
| Section 122 Clause Tax | +10.0% (Specific clause tax for this category) |
| Total Tax Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| Legal Basis | Base Tariff (3.7%) + Sec 301 (25%) + Sec 122 (10%) |
π Explanation:
- The 3.7% base rate reflects the standard Most Favored Nation (MFN) duty for halogenated hydrocarbons.
- The 25% is the standard Section 301 tariff on many Chinese chemical products.
- The 10% is an additional layer specified in the provided data under "122ζ‘ζ¬Ύε ³η¨" (Clause 122 Tax).
- Total: 38.7%. This is the lower of the two main tax brackets provided.
π― 2. Chapter 38 Codes: 3811.19.00.00, 3811.90.00.00, & 3824.99.50.00
(For HCFC mixtures, preparations, and additives)
| Item | Content |
|---|---|
| Base Tariff | 6.5% |
| Section 301 Surtax | +25.0% (25% additional duty on Chinese goods) |
| Section 122 Clause Tax | +10.0% (Specific clause tax for this category) |
| Total Tax Rate | 41.5% |
| Tax Calculation | CIF Value Γ 41.5% |
| Legal Basis | Base Tariff (6.5%) + Sec 301 (25%) + Sec 122 (10%) |
π Explanation:
- The 6.5% base rate applies to "chemical preparations" and "mixtures" in Chapter 38.
- The 25% Section 301 surcharge applies uniformly.
- The 10% Clause 122 tax is applied here as well.
- Total: 41.5%. This is 2.8% higher than Chapter 29 codes.
π οΈ IV. Customs Clearance Practical Advice (Avoiding Pitfalls)
β 1. Documentation Checklist (Mandatory)
| Document | Required | Notes |
|---|---|---|
| Product Specification Sheet | βοΈ | Must clearly state chemical composition (pure compound vs. mixture). |
| Certificate of Analysis (CoA) | βοΈ | Essential to prove if the product is a single HCFC compound (Chapter 29) or a blend (Chapter 38). |
| Safety Data Sheet (SDS) | βοΈ | Indicates chemical hazards and composition. |
| Commercial Invoice | βοΈ | Must accurately describe the product as "HCFC Refrigerant" with HS Code. |
| Packing List | βοΈ | Include net/gross weight and container numbers. |
| Certificate of Origin | βοΈ | Required for US customs; confirms Chinese origin for surcharge application. |
| Import License (If Applicable) | βοΈ | Some HCFCs may require EPA or specific import permits due to Montreal Protocol regulations. |
β 2. Classification Strategy (Key Decision Points)
π₯ "Pure vs. Mix: Define It Clearly, Tax Can Be Lower!"
| Scenario | Recommended HS Code | Tax Rate | Risk if Misclassified |
|---|---|---|---|
| Pure R-22 or R-141b | 2903.71.01.00 or 2903.75.01.00 |
38.7% | If declared as mixture β 41.5% (overpayment). |
| Refrigerant Blend (e.g., R-404A, R-410A) | 3811.19.00.00 or 3824.99.50.00 |
41.5% | If declared as pure compound β Severe Penalty for false declaration. |
| HCFC with Additives/Anti-knock Agents | 3811.19.00.00 |
41.5% | Must declare as preparation, not pure compound. |
| General HCFC Mixture | 3824.99.50.00 |
41.5% | Fallback for undefined mixtures of halogenated hydrocarbons. |
β 3. Special Cases & Handling
| Situation | Handling Advice |
|---|---|
| OEM Blended Refrigerants | Provide detailed CoA showing all components. Classify as Chapter 38. |
| Refrigerant with Trace Impurities | If purity >95% and single compound, argue for Chapter 29. If impurities form a distinct mixture, Chapter 38. |
| Environmental Compliance | Ensure EPA Section 608 compliance. HCFCs are phased out; imports may be restricted unless for servicing existing equipment. |
| Packaging | Ensure cylinders/tanks are UN-certified for dangerous goods transport. |
π V. Global Market Comparison (2026 Context)
| Country/Region | Recommended HS Code | Base Tax | Surcharges (China) | Total Tax | Notes |
|---|---|---|---|---|---|
| πΊπΈ USA | 2903.71.01.00 / 3811.19.00.00 |
3.7% / 6.5% | +25% (Sec 301) + 10% (Clause 122) | 38.7% / 41.5% | High tariffs. Strict EPA rules. |
| π¨π³ China | 2903.71.01.00 / 3811.19.00.00 |
~3-6% | None | ~3-6% | No surcharges for domestic consumption. |
| πͺπΊ EU | 2903.71.00 / 3824.99 |
0-6.5% | None | 0-6.5% | No US-style surcharges. F-Gas Regulation applies. |
| π―π΅ Japan | 2903.71.00 / 3824.99 |
0-6% | None | 0-6% | No surcharges. Strict environmental labeling. |
π Conclusion:
- USA imposes significant duties due to geopolitical tariffs.
- Chapter 29 (Pure Compounds) is 2.8% cheaper than Chapter 38 (Mixtures).
- Accurate Chemical Declaration is critical to avoid penalties and overpayment.
π VI. Common Errors & Pitfalls (Lessons Learned)
β Error 1: Declaring a blend (e.g., R-404A) as a pure compound (e.g., R-125).
π Consequence: Customs may classify it as Chapter 38 (41.5%) or impose fraud penalties.
π Solution: Always use CoA to prove composition.
β Error 2: Ignoring the 10% Clause 122 Tax.
π Consequence: Underpayment of duties, leading to interest and fines.
π Solution: Include all surcharges in cost calculations.
β Error 3: Mislabeling additive-containing refrigerants as pure refrigerants.
π Consequence: Wrong HS Code (2903 instead of 3811).
π Solution: If additives are present, it's a "preparation" β Chapter 38.
β Error 4: Failing to disclose Montreal Protocol restrictions.
π Consequence: Shipment seizure by EPA/CBP if not for eligible servicing.
π Solution: Provide EPA compliance documents and end-use certification.
β Correct Practice:
"HCFC Refrigerant Mixture (e.g., R-410A), 99% Pure, for HVAC Servicing, Compliant with EPA Section 608, HS Code: 3811.19.00.00"
π― VII. Conclusion: Precision in Classification Saves Money
π― Remember the Key Rules:
πΉ "Pure = Chapter 29 (38.7%), Mixture = Chapter 38 (41.5%)"
πΉ "Always declare chemical composition accurately"
πΉ "Include all surcharges: Base + 25% + 10%"
πΉ "Check EPA regulations before shipping"
π Pro Tip:
If your HCFC product is blended or contains additives, you must use Chapter 38 codes (3811 or 3824). Do not attempt to classify blends as pure compounds under Chapter 29, as this is a common audit trigger.
π£ Immediate Action:
π Consult with a customs broker to verify if your HCFC formula is considered a "pure compound" or a "mixture."
π Obtain a detailed Certificate of Analysis (CoA) from your manufacturer.
π Ensure EPA compliance to avoid shipment rejection.
β¨ Accurate classification is the first step to cost-effective global trade!
πΌ Every percent of duty saved is pure profit!
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.