Hairless Horse Leather Side Panel
CN → US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 4106910000 | 38.3% | CN | US | Official Doc |
| 4106920000 | 38.3% | CN | US | Official Doc |
| 4101901040 | 17.5% | CN | US | Official Doc |
| 4101907000 | 20.8% | CN | US | Official Doc |
| 4107917090 | 15.0% | CN | US | Official Doc |
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AI Analysis
🐎 Hairless Horse Leather Side Panel (Rawhide/Unprocessed)
🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
📌 I. Product Definition & Classification: What Exactly is a "Hairless Horse Leather Side Panel"?
This product consists of horse hides/skins that have been processed into side panels (major sections of the hide) but remain in a hairless state. The key classification factor lies in the degree of tanning/processing:
- Rawhide/Unprocessed (生皮): Not tanned, or only preserved (e.g., salted, lime-treated) without reaching the "pelt" state. Usually classified under Chapter 41, Heading 4101.
- Unfinished Tanned/Chrome Tanned Side Panels (半成品/侧片): Tanned but not further dressed, colored, or finished for direct end-use. Often classified under Chapter 41, Heading 4106 or 4107 depending on the specific type of tanning and further processing status.
- Key Distinction:
- If it is raw/un-tanned → Look at 4101.
- If it is tanned (e.g., chrome) but un-finished → Look at 4106 or 4107.
- "Hairless" implies the hair has been removed, but it doesn't necessarily mean it's "finished leather."
⚠️ Critical Classification Point:
- If it is raw, un-tanned horsehide, it falls under 4101.90.
- If it is tanned (e.g., chrome-tanned) but not further processed, it often falls under 4106.92 or 4106.91.
- If it is further processed but not made up (e.g., specific side panels for automotive), it might fall under 4107.91 or 4107.99.
📦 II. HS Code Classification Details (2026 Latest Tariff Reference)
| HS Code | Product Description | Application Scenario | Processing State |
|---|---|---|---|
4101.90.10.40 |
Other parts of raw horsehides/skins (side panels) | Raw, un-tanned horsehide sides, possibly salted | ✅ Raw (Un-tanned) |
4101.90.70.00 |
Other raw horsehides/skins (side panels) | Raw horsehide sides, general classification | ✅ Raw (Un-tanned) |
4106.91.00.00 |
Chrome-tanned side panels of horsehide | Tanned (chrome) but un-finished, hairless | ✅ Tanned (Chrome) |
4106.92.00.00 |
Other tanned side panels of horsehide | Tanned (vegetable/others) but un-finished | ✅ Tanned (Other) |
4107.91.70.90 |
Other prepared leather side panels (non-specific use) | Tanned and further processed (not specific automotive/seat) | ✅ Further Processed |
🔍 Key Reminder:
- "Hairless" (无毛) is a condition, but the tanning state determines the heading.
- Rawhide (4101) is subject to different tax rates than Tanned Leather (4106/4107).
- "Side Panel" (侧片) refers to the major sections of the hide, not whole hides.
💰 III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
✅ Applicable Country: USA (US)
✅ Country of Origin: China (CN)
✅ Effective Date: From Nov 10, 2025 (and subsequent imports)
🎯 1. 4101.90.10.40 – Raw Horsehide Side Panels (Other Parts)
| Item | Content |
|---|---|
| Base Tariff | 0.0% (ad valorem) |
| USITC Surcharge | +7.5% (Section 301 Duty) |
| IEEPA Surcharge | +10% (China-specific, under IEEPA) |
| Total Tariff | 17.5% |
| Tax Calculation | CIF Value × 17.5% |
| De Minimis Eligibility | ❌ Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:4101.90.10.40 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- Base rate is low (0%), but USITC 7.5% and IEEPA 10% apply.
- This is the lowest total tariff among the listed options.
🎯 2. 4101.90.70.00 – Raw Horsehide Side Panels (Other)
| Item | Content |
|---|---|
| Base Tariff | 3.3% (ad valorem) |
| USITC Surcharge | +7.5% |
| IEEPA Surcharge | +10% |
| Total Tariff | 20.8% |
| Tax Calculation | CIF Value × 20.8% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:4101.90.70.00 |
📌 Note:
- Slightly higher base rate (3.3%) than4101.90.10.40.
- Still cheaper than tanned leather options.
🎯 3. 4106.91.00.00 – Chrome-Tanned Horsehide Side Panels
| Item | Content |
|---|---|
| Base Tariff | 3.3% (ad valorem) |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10% |
| Total Tariff | 38.3% |
| Tax Calculation | CIF Value × 38.3% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:4106.91.00.00 → FOOTNOTE:9903.88.01 |
📌 Explanation:
- High tariff (38.3%) due to 25% USITC surcharge on tanned leather.
- Significantly more expensive than rawhide.
🎯 4. 4106.92.00.00 – Other Tanned Horsehide Side Panels
| Item | Content |
|---|---|
| Base Tariff | 3.3% |
| USITC Surcharge | +25.0% |
| IEEPA Surcharge | +10% |
| Total Tariff | 38.3% |
| Tax Calculation | CIF Value × 38.3% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:4106.92.00.00 |
📌 Note:
- Same as4106.91.00.00.
- Tanned leather attracts higher duties.
🎯 5. 4107.91.70.90 – Prepared Horsehide Side Panels (Other)
| Item | Content |
|---|---|
| Base Tariff | 5.0% |
| USITC Surcharge | 0.0% (Exempt or not applicable) |
| IEEPA Surcharge | +10% |
| Total Tariff | 15.0% |
| Tax Calculation | CIF Value × 15.0% |
| De Minimis Eligibility | ❌ Not Eligible |
| Legal Basis Path | IEEPA:9903.01.25 → USITC:4107.91.70.90 |
📌 Explanation:
- Lowest total tariff (15.0%) if classified here.
- No USITC surcharge (0%).
- This is likely the most cost-effective option if the product qualifies as "prepared leather" rather than "tanned but unfinished."
🛠️ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
✅ 1. Documentation Checklist (Essential)
| Document | Required | Description |
|---|---|---|
| ✅ Product Specification Sheet | ✔️ | Must specify: Horsehide, Side Panel, Hairless, Tanning Method (None/Chrome/Vegetable) |
| ✅ Photos (Clear Label) | ✔️ | Show texture, edges, and any markings. Prove it's "side panel" not whole hide. |
| ✅ Tanning Certificate | ✔️ | Critical for distinguishing between 4101 (Raw), 4106 (Tanned), and 4107 (Prepared) |
| ✅ Commercial Invoice | ✔️ | Use precise description: "Hairless Horse Leather Side Panel, Chrome Tanned" or "Raw Horsehide Side Panel" |
| ✅ Packing List | ✔️ | Detail weight, dimensions, and quantity. |
✅ 2. Declaration Tips (Key Mantra)
🔥 "Tanning State Determines HS Code; Tax Rate Varies by 23%!"
| Scenario | Correct Declaration | Risk of Error |
|---|---|---|
| Rawhide (Un-tanned) | 4101.90.10.40 or 4101.90.70.00 |
Tax: 17.5% - 20.8% |
| Tanned but Un-finished | 4106.91.00.00 or 4106.92.00.00 |
Tax: 38.3% (High Risk) |
| Prepared Leather | 4107.91.70.90 |
Tax: 15.0% (Lowest) |
📌 Critical:
- If you declare Tanned but it's Raw, you may face under-declaration penalties.
- If you declare Raw but it's Tanned, you may face over-declaration or classification error penalties.
- Proof of Tanning Process is essential.
✅ 3. Special Handling
| Scenario | Recommendation |
|---|---|
| OEM/Custom Product | Provide design specs to prove it's a "side panel" and not "made-up leather goods." |
| Mixed Shipments | Do not mix rawhide and tanned leather in one HS Code declaration. |
| Pre-Ruling | Apply for Advance Ruling to confirm if it falls under 4101 (Raw) or 4106/4107 (Tanned/Prepared). |
🌍 V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate (China Origin) | Notes |
|---|---|---|---|
| 🇺🇸 USA | 4107.91.70.90 |
15.0% | Lowest US Tariff |
| 🇺🇸 USA | 4101.90.10.40 |
17.5% | Low if Raw |
| 🇺🇸 USA | 4106.91.00.00 |
38.3% | High due to Surtax |
| 🇨🇳 China | 4101.90.10.40 |
~5-13% | Import Duty |
| 🇪🇺 EU | 4107.91.70.90 |
~0-6% | Check EBA/GSP |
| 🇬🇧 UK | 4107.91.70.90 |
~0-6% | Post-Brexit Tariff |
📌 Conclusion:
- USA is the most complex due to Section 301 and IEEPA surcharges.
- Prepared Leather (4107) has the lowest US tariff (15%).
- Rawhide (4101) is also low (17.5%) but requires strict proof of un-tanned state.
- Tanned Leather (4106) is the most expensive (38.3%).
📌 VI. Common Errors & Pitfalls (Lessons Learned)
❌ Error 1: Declaring Tanned Leather as Rawhide to save tax
👉 Consequence: Customs inspection reveals tanning agents → Penalties + Back Taxes.
❌ Error 2: Declaring Rawhide as Tanned unnecessarily
👉 Consequence: Higher tax (38.3% vs 17.5%) → Lost Profit.
❌ Error 3: Ambiguous description: "Leather Side Panel"
👉 Consequence: Customs cannot determine HS Code → Delay + Inspection.
❌ Error 4: Ignoring IEEPA 10% surcharge
👉 Consequence: Unexpected tax bill at customs → Cash Flow Issue.
✅ Correct Practice:
"Hairless Horse Leather Side Panel, Chrome Tanned, Unfinished, for Automotive Upholstery, Model XYZ"
→ Classify under4106.91.00.00(if unfinished) or4107.91.70.90(if prepared).
🎯 VII. Conclusion: Precision in Classification Saves Money!
🎯 Key Takeaway:
🔹 "Rawhide: 17.5% | Tanned: 38.3% | Prepared: 15.0%"
🔹 "HS Code Choice = Tax Savings of up to 23%!"
🔹 "Always Provide Tanning Proof!"
📌 Pro Tip:
If your product is prepared leather (tanned + finished/dressed), aim for
4107.91.70.90(15.0%) for the lowest US tariff.
If it is raw, use4101.90.10.40(17.5%).
Avoid4106if possible due to 38.3% tariff.
📣 Immediate Action:
📞 Consult a Customs Broker + Provide Tanning Certificate + Apply for HS Code Advance Ruling
🚀 Ensure Smooth Clearance, Minimize Taxes, and Maximize Profit!
✨ Professional Customs Clearance Starts with Accurate Classification!
💼 Every Percent of Tax Saved is Pure Profit!
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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) — Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) — More specific grouping within the chapter
- Subheading (6 digits) — Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) — 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 — The standard duty rate applied to WTO members
- General rate — Applied to countries without trade agreements
- Trade remedy duties — 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.