Hairless Cowhide (for Clothing)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 4107115000 | 12.8% | CN | US | Official Doc |
| 4107111020 | 35.0% | CN | US | Official Doc |
| 4107127040 | 15.0% | CN | US | Official Doc |
| 4107117040 | 15.0% | CN | US | Official Doc |
| 4104111020 | 35.0% | CN | US | Official Doc |
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AI Analysis
π Hairless Cowhide (for Clothing)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "Hairless Cowhide"?
Hairless Cowhide for Clothing refers to bovine leather that has undergone specific tanning and processing processes (such as de-hairing, splitting, and finishing) to remove the original hair layer while maintaining the leather's structural integrity. In international trade, it is strictly classified based on its physical state (e.g., chrome-tanned vs. vegetable-tanned, semi-processed vs. fully processed) and specific application (clothing).
β οΈ Key Distinction:
- Fully Processed/Finished Leather (Chrom-tanned, ready-to-use): Typically falls under 4107. These are "ready-to-wear" components.
- Semi-Processed/Unfinished Leather (Raw chrome-tanned, need further processing): Typically falls under 4104. These require additional manufacturing before becoming clothing.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Processing State |
|---|---|---|---|
4107.12.70.40 |
De-haired Cowhide for Apparel (Non-Top Grain) | Garment linings, cheaper fashion accessories, inner layers | β Ready-to-use (Non-top grain) |
4107.11.70.40 |
De-haired Cowhide for Apparel (Top Grain/Full Grain) | High-end jackets, belts, premium apparel components | β Ready-to-use (Top Grain) |
4104.11.10.20 |
Unfinished Chrome-Tanned Bovine Leather (For Clothing) | Bulk leather requiring further dyeing/finishing before garment production | β οΈ Semi-processed |
4104.49.10.20 |
Other Unfinished Bovine Leather Pieces (For Clothing) | Various forms of unfinished leather cuts for clothing manufacturing | β οΈ Semi-processed |
4107.11.10.20 |
Full-Grain De-haired Cowhide (Ready-to-use) | Premium clothing components, high-quality leather goods | β Ready-to-use (Full Grain) |
π Key Reminder:
- Ready-to-use leather (tanned, de-haired, finished) generally falls under 4107.
- Semi-processed leather (chrome-tanned but not yet finished for direct use) generally falls under 4104.
- Misclassification between 4104 and 4107 can lead to significant tariff differences due to different surtax structures.
π° III. 2026 Latest Tariff Rate Details (Including Surcharge & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: 2025/2026 Import Period
π― 1. Group A: Ready-to-Use Apparel Leather (HS Codes 4107.x)
Includes: 4107.12.70.40 and 4107.11.70.40
| Item | Content |
|---|---|
| Base Tariff | 5.0% (Ad Valorem) |
| Section 301 Surcharge | 0.0% |
| 122 Clause Surcharge | 10.0% (Specific to certain leather goods/apparel components) |
| Total Tariff Rate | 15.0% |
| Tax Calculation | CIF Value Γ 15% |
| De Minimis Exemption | β Not Applicable (Deny De Minimis for leather goods from China) |
| Legal Basis Path | HTS:4107.xx.xx.xx β Section 301: Footnote 1 β 122 Clause: Special Regime |
π Explanation:
- Base Tariff 5%: Standard MFN (Most Favored Nation) rate for prepared leather.
- 122 Clause 10%: This is a critical add-on. While some leather goods may be exempt from broader Section 301 tariffs, specific categories of leather products intended for apparel are subject to this separate 10% surcharge.
- Total 15%: This is the effective landed cost multiplier.
π― 2. Group B: Semi-Processed/Unfinished Leather (HS Codes 4104.x)
Includes: 4104.11.10.20, 4104.49.10.20, and 4107.11.10.20 (Note: 4107.11.10.20 is listed with higher tax in data, likely due to specific sub-classification or data anomaly, but aligns with 4104 logic in base rate 0%)
| Item | Content |
|---|---|
| Base Tariff | 0.0% (Ad Valorem) |
| Section 301 Surcharge | 25.0% (Standard 301 List 4A rate for many leather products) |
| 122 Clause Surcharge | 10.0% |
| Total Tariff Rate | 35.0% |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Exemption | β Not Applicable |
| Legal Basis Path | HTS:4104.xx.xx.xx β Section 301: Footnote 9903.88.01 β 122 Clause: Special Regime |
π Explanation:
- Base Tariff 0%: Many unfinished or semi-finished leather goods enjoy a low base duty.
- Section 301 25%: A significant punitive tariff applied to Chinese-made leather products under Section 301.
- 122 Clause 10%: An additional layer of protectionist duty.
- Total 35%: This is a very high tariff compared to the 15% for finished apparel leather. Proper classification is crucial to avoid unexpected costs if the product is actually "ready-to-use."β οΈ Data Note on
4107.11.10.20:
The provided data lists4107.11.10.20(Full-Grain De-haired Cowhide) with a 35% tax rate (0% Base + 25% + 10%). This suggests that despite being under Heading 4107 (Finished), this specific sub-code may trigger the Section 301 25% surcharge due to its classification as "Top Grain" or specific processing type, unlike the 4107.11.70.40 / 4107.12.70.40 codes which only carry the 10% 122 clause. This distinction is vital.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
β 1. Document Checklist (Essential for Clearance)
| Document | Mandatory? | Description |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state: "De-haired," "Tanning Method (Chrome/veg)," "End Use: Clothing," "Is it Top Grain?" |
| β Photos of Leather | βοΈ | Show surface texture, edges, and any markings. Distinguish between "finished" (smooth, dyed) vs. "semi-processed" (raw, pale). |
| β Commercial Invoice | βοΈ | Must explicitly state "For Clothing Use" and match HS Code descriptions exactly. |
| β Packing List | βοΈ | Detail weight and dimensions. |
| β Certificate of Origin | βοΈ | Required for origin verification and surcharge application. |
| β Third-Party Test Report | βοΈ | If available, include chemical test reports to confirm chrome content or finishing processes. |
β 2. Classification Strategy & Tips (Key Mantra)
π₯ βFinish Level Determines Tax! Ready-to-Use 15%, Unfinished 35%!β
| Scenario | Correct Classification | Wrong Classification | Consequence |
|---|---|---|---|
| Finished, Dyed, Ready for Garment Cutting | 4107.12.70.40 or 4107.11.70.40 |
4104.x.x.x |
Paying 35% instead of 15% (Loss of 20%) |
| Raw Chrome Tanned, Needs Dyeing/Finishing | 4104.11.10.20 or 4104.49.10.20 |
4107.x.x.x |
Paying 35% instead of 15% (if it can be argued as ready-to-use) or correct 35% |
| Full-Grain Premium (Special Sub-code) | 4107.11.10.20 |
4107.11.70.40 |
Paying 35% instead of 15% (Critical Check!) |
| Leather Scraps/Waste | Different Code (98.xx) | 4107 |
Potential fraud penalty if misdeclared as usable leather |
β 3. Special Handling Advice
| Situation | Recommendation |
|---|---|
| Ambiguous "Finished" State | If the leather is partially finished, provide a Detailed Process Description (e.g., "Chrome Tanned, Drum Dye, Light Finish, Ready for Cutting"). Argue for 4107 if possible to save 20%. |
| Mixed Shipments | Do not mix 4107 and 4104 codes in one HS line item. Declare separately to avoid customs rejection. |
| 122 Clause Specifics | Ensure the product description explicitly mentions "For Clothing" to trigger the correct 122 clause applicability. If used for automotive upholstery, different rates may apply. |
| Origin Marking | Ensure "Made in China" is clearly marked on packaging, as surcharges are origin-specific. |
π V. Global Market Comparison (2026 Update)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ United States | 4107.12.70.40 / 4107.11.70.40 |
15% (10% 122 Clause + 5% Base) | High compliance risk due to 122 Clause. |
| πΊπΈ United States | 4104.x.x.x |
35% (25% 301 + 10% 122) | Avoid if possible by proving "Ready-to-Use" status. |
| π¨π³ China | 4107 |
~5-10% | Lower impact for exports back to China. |
| πͺπΊ EU | 4107 |
0-6.5% | No major Section 301/122 equivalents. |
| π―π΅ Japan | 4107 |
5-10% | Standard MFN rates apply. |
π Conclusion:
- The US market is the most complex for leather goods due to the 122 Clause and Section 301 interactions.
- Maximize the 15% rate by ensuring products are classified under 4107 (Finished/Ready-to-Use) rather than 4104 (Semi-Processed).
- Verify the specific sub-code for full-grain leather (4107.11.10.20) as it may carry a higher tax burden than standard apparel leather (4107.11.70.40).
π VI. Common Errors & Pitfalls (Lessons Learned)
β Error 1: Classifying all cowhide under 4104 (Unfinished) |
π Result: Paying 35% tax when the product is actually ready-to-use (15%). Loss of 20% margin!
β Error 2: Assuming all 4107 codes have the same tax rate |
π Result: Misclassifying 4107.11.10.20 (35%) as 4107.11.70.40 (15%). Unexpected 20% surcharge!
β Error 3: Ignoring the "For Clothing" specification |
π Result: Customs may reclassify under different headings with different 122 clause applicability, leading to delays or higher duties.
β Error 4: Not providing photo evidence of the leather finish |
π Result: Customs cannot verify if the leather is "finished" or "semi-finished," leading to potential audit penalties.
β Correct Approach:
"Chrome-Tanned, De-Haired, Full-Grain Cowhide Leather, Dyed Black, Lightly Finished, Specifically Cut for Menβs Leather Jackets, Model ABC, Origin: China."
π― VII. Conclusion: Precise Classification Saves Money!
π― Remember the Mantra:
πΉ "Finished Leather = 15% (4107); Unfinished = 35% (4104)."
πΉ "Check the Sub-Code: Full-Grain Premium May Cost More (35%)."
πΉ "122 Clause Adds 10% to Almost All Leather Imports."
π Pro Tip:
If your leather is partially finished, invest in a Customs Ruling Request before shipment. It provides legal certainty and prevents unexpected 35% duties.
π£ Immediate Action:
π Contact a licensed customs broker.
πΈ Provide high-res photos of the leather surface.
π Ensure your invoice clearly states "Ready-to-Use for Clothing."
π Avoid costly classification errors and maximize your profit margin!
β¨ Professional Clearance, Start with Accurate Classification!
πΌ Every percentage point of tariff impacts your bottom line!
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.