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Halogen containing waste solvent

CN β†’ US
HS Code Tariff Rate Origin Destination Doc
3824995500 38.7% CN US Official Doc
3824995000 41.5% CN US Official Doc

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πŸ§ͺ Halogen Containing Waste Solvent (Industrial Chemical Byproducts)


🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
πŸ“Œ I. Product Definition & Classification: Do You Really Know "Halogenated Waste Solvent"?

Halogen-containing waste solvent refers to spent chemical mixtures containing halogenated hydrocarbons (such as chlorinated, brominated, or mixed halogens) that are no longer suitable for their original industrial purpose. In international trade, these are classified under Chapter 38 as "Prepared binders for foundry molds or cores" or "Chemical products and preparations... not elsewhere specified."

Crucially, classification depends on the specific halogen type and chemical composition:

1. Mixtures of Halogenated Hydrocarbons (General/Misc):
- Contains a blend of halogenated compounds not specifically listed as "chlorinated but not otherwise halogenated."
- Often includes complex industrial waste streams containing multiple halogens or non-standard mixtures.

2. Chlorinated but Not Otherwise Halogenated:
- Specifically refers to mixtures where Chlorine is the primary or sole halogen component, and no other halogens (Bromine, Fluorine, Iodine) are present in significant quantities.
- Examples: Spent trichloroethylene, perchloroethylene, or simple chlorinated hydrocarbon blends.

⚠️ Key Distinction Point:
- If the waste contains Bromine, Fluorine, or a mix of halogens, or is a complex mixture not defined as "Chlorinated only" β†’ It falls under "Other" (HS 3824.99.55.00).
- If the waste is exclusively Chlorinated hydrocarbons (no other halogens) β†’ It falls under "Chlorinated but not otherwise halogenated" (HS 3824.99.50.00).


πŸ“¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)

Based strictly on the provided data <DATA>:

HS Code Product Description Applicability Halogen Type Tax Rate (Total)
3824.99.55.00 Other: Other: Other: Other: Mixtures of halogenated hydrocarbons: Other General mixtures, non-chlorine-only, or complex halogen blends Mixed/Other Halogens 28.7%
3824.99.50.00 Other: Other: Other: Other: Mixtures of halogenated hydrocarbons: Chlorinated but not otherwise halogenated Pure chlorinated hydrocarbon waste (e.g., spent degreasers without Br/F/I) Chlorine Only 0.0%

πŸ” Critical Reminder:
- 3824.99.55.00 carries a high tariff burden (28.7%) due to the "25% Additional Tariff" (Section 301) applied to general halogenated waste.
- 3824.99.50.00 is exempt from additional tariffs (0.0%) if strictly "Chlorinated but not otherwise halogenated."
- Misclassification Risk: Declaring a mixed-halogen waste as "Chlorinated only" to avoid tariffs is considered fraud. Customs requires chemical composition proof.


πŸ’° III. 2026 Latest Tariff Rate Breakdown (Detailed Policy Analysis)

βœ… Applicable Country: United States (US)
βœ… Origin: China (CN) (Inferred from tax details: 25% Additional Tariff is a Section 301 China-specific tariff)
βœ… Effective Date: 2025/2026 (Current Trade War Tariffs)

🎯 1. 3824.99.55.00 β€”β€” Halogenated Hydrocarbon Mixtures (Other)

Item Detail
Base Duty Rate 3.7% (Ad valorem)
USITC Additional Tariff (Section 301) +25.0% (On Chinese origin goods)
Total Effective Tax Rate 28.7%
Tax Calculation CIF Value Γ— 28.7%
De Minimis Exemption ❌ NOT Eligible
Chemical waste/hazardous materials are excluded from Section 321 (De Minimis) benefits.
Legal Basis Path USITC:3824.99.55.00 β†’ Section 301 Footnote β†’ China Origin

πŸ“Œ Explanation:
- The 3.7% is the standard Most Favored Nation (MFN) duty.
- The 25% is a punitive tariff under Section 301 of the Trade Act of 1974, specifically targeting Chinese imports of certain industrial chemicals and waste products.
- Total 28.7% is significant. Importers must budget for this high clearance cost.


🎯 2. 3824.99.50.00 β€”β€” Chlorinated but Not Otherwise Halogenated

Item Detail
Base Duty Rate 0.0%
USITC Additional Tariff (Section 301) 0.0% (Exempt from current Section 301 lists for this specific subheading)
Total Effective Tax Rate 0.0%
Tax Calculation $0 (No duty payable)
De Minimis Exemption ❌ NOT Eligible
Despite 0% duty, hazardous/waste status still blocks De Minimis clearance.
Legal Basis Path USITC:3824.99.50.00 β†’ No Section 301 Footnote Applied

πŸ“Œ Note:
- This is a zero-duty entry point for chlorinated waste solvents.
- Strict Condition: The chemical must be proven to contain no other halogens (Bromine, Fluorine, Iodine). If even trace amounts of Bromine are found, customs may reclassify to 3824.99.55.00 and apply the 28.7% rate + penalties.


πŸ› οΈ IV. Customs Clearance Practical Advice (Battle-Tested Pitfall Guide)

βœ… 1. Required Documentation Checklist (Non-Negotiable)

Document Mandatory? Description
βœ… Safety Data Sheet (SDS) βœ”οΈ Must be Section 15 compliant, clearly stating chemical composition and halogen content.
βœ… Certificate of Analysis (COA) βœ”οΈ Lab report confirming % of Chlorine vs. other halogens. Essential for 3824.99.50.00 claim.
βœ… Waste Hazardous Waste Manifest βœ”οΈ EPA RCRA documentation proving legal export/import status.
βœ… Commercial Invoice βœ”οΈ Must state: "Halogenated Waste Solvent, [Specify Type], CN Origin, HS Code 3824.99.xxxx"
βœ… Packing List βœ”οΈ Detail net/gross weight, container number, and UN Number (e.g., UN1993).
βœ… Importer Security Filing (ISF) βœ”οΈ File 10 days before loading. Incorrect HS code leads to $5,000 fines per violation.

βœ… 2. Declaration Strategy (Key Mnemonic)

πŸ”₯ "Halogen Type Dictates Tax: Chlorine Only is Free, Mixed is Heavy!"

Scenario Correct HS Code Tax Rate Risk if Misclassified
Mixed Halogen Waste (e.g., Chloro + Bromo) 3824.99.55.00 28.7% If declared as "Chlorine Only" β†’ Back Taxes + 25% Penalty
Pure Chlorinated Waste (e.g., Spent TCE) 3824.99.50.00 0.0% If declared as "Other" β†’ Overpaid duty (minor loss, but bad practice)
Non-Halogenated Waste (e.g., Acetone) Not in Data See other chapters Do not use Chapter 38 codes

βœ… 3. Special Case Handling

Situation Handling Advice
OEM/Contract Manufacturing Waste Provide the contract and formulation sheet. Prove if the waste is from a specific Chinese manufacturer subject to Section 301.
Re-imported Used Solvent Check if the solvent has been "spent" or just "used." If reused, it may not be "waste." If waste, RCRA rules apply.
Transshipment via Third Country High Risk. US Customs tracks origin. If Chinese waste is transshipped, it is still subject to 28.7% if it falls under 3824.99.55.00.
Small Quantity Samples No De Minimis. Even small amounts of hazardous halogenated waste require formal entry and duty payment.

🌍 V. Global Market Clearance Comparison (2026 Latest)

Country/Region Recommended HS Code Duty Rate Certification Notes
πŸ‡ΊπŸ‡Έ USA 3824.99.55.00 (Mixed) 28.7% EPA RCRA, SDS 3824.99.50.00 is 0% if pure chlorinated.
πŸ‡ΊπŸ‡Έ USA 3824.99.50.00 (Chlorine) 0.0% EPA RCRA, SDS Zero duty, but strict compliance on halogen type.
πŸ‡ͺπŸ‡Ί EU 3825.49.00 Varies (0-5%) REACH, WEEE EU has different waste solvents classification.
πŸ‡¨πŸ‡³ China 3825.49.00 5-10% HS Code varies Import of waste solvents is heavily restricted.

πŸ“Œ Conclusion:
- USA is the most complex market due to the 25% Section 301 tariff on general halogenated waste.
- Optimization Strategy: If the waste is purely chlorinated, ensure the COA clearly states "No Bromine, Fluorine, or Iodine" to qualify for 0% duty under 3824.99.50.00.
- Do not assume "Halogenated" = "Chlorinated." Mixed wastes are taxed heavily.


πŸ“Œ VI. Common Errors & Pitfalls (Lessons Learned)

❌ Error 1: Declaring "Mixed Halogen Waste" as "Chlorinated" to save 25%
πŸ‘‰ Consequence: Customs lab test reveals Bromine/Fluorine β†’ Reclassification to 3824.99.55.00 + Back Taxes + Penalty (25% of duty evaded).

❌ Error 2: Using De Minimis (Section 321) for small shipments
πŸ‘‰ Consequence: Seizure and Destruction by CBP. Hazardous waste is explicitly excluded from De Minimis.

❌ Error 3: Vague Description "Chemical Waste"
πŸ‘‰ Consequence: CBP exam delay. Customs cannot determine HS code without Halogen Type specified. Result: Hold until SDS/COA provided.

❌ Error 4: Ignoring EPA RCRA Regulations
πŸ‘‰ Consequence: Import Refusal. Even if duties are 0%, lack of EPA registration/manifest leads to return or destruction of goods.

βœ… Correct Practice:

"Halogenated Waste Solvent, Mixture of Chlorinated and Brominated Hydrocarbons, CN Origin, For Industrial Degreasing Recycling, HS 3824.99.55.00, SDS Attached"


🎯 VII. Conclusion: Precise Classification Saves Money!

🎯 Remember the Mnemonic:

πŸ”Ή "Chlorine Only = Zero Tax, Mixed Halogens = 28.7% Pain!"
πŸ”Ή "No De Minimis for Waste, SDS and COA are Key!"


πŸ“Œ Pro Tip:
If your waste is 100% Chlorinated, invest in a Certificate of Analysis (COA) from an accredited lab to prove Zero Bromine/Fluorine. This can save you 25% in duties on every shipment.


πŸ“£ Immediate Action:

πŸ“ž Audit your chemical composition.
πŸ“„ Obtain a fresh COA.
πŸš€ Declare with precision.
Let your halogenated waste clear smoothly, legally, and cost-effectively!


✨ Professional clearance starts with precise chemical classification!
πŸ’Ό Every percentage point in duty matters in international trade!

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.