Hardware Code 4107196010
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π Full Grain Cow Leather (Harware Code 4107196010)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "Full Grain Cow Leather"?
Full grain cow leather is the highest grade of genuine leather, retaining the natural grain surface with the original hide structure intact. In international trade, it is primarily classified under Chapter 41 (Animal Skins and Furs).
Specifically, HS Code 4107.19.60.10 typically refers to:
"Other full grain leather, of bovine (including buffalo) animals, tanned or chrome tanned, whether or not split, but not further tanned, dressed, or finished."
β οΈ Key Distinction Points: - Full Grain vs. Top Grain: "Full Grain" retains the natural markings; "Top Grain" is sanded/finished. For HS Code purposes, both often fall under 4107 if not further finished, but "Full Grain" implies higher value and specific origin claims. - Chrome Tanned vs. Vegetable Tanned: Chrome tanned (most common for apparel/bags) falls under 4107. Vegetable tanned also falls under 4107 but may have different duty structures depending on the country. - Further Processed? If the leather is colored, coated, or heavily finished (beyond standard tanning/dressing), it may move to 4104 or 4106. 4107 is for leather that is tanned but not "finished" in the sense of being ready for end-use without further manufacturing (like painting or embossing).
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Tanning Method | Further Processed? |
|---|---|---|---|---|
4107.19.60.10 |
Full grain cow leather, tanned/chrome tanned, not further finished | Raw leather for bags, shoes, belts | Chrome or Vegetable | β No (Just tanned/dressed) |
4104.19.00.00 |
Tanned leather, finished/colored, of bovine animals | Finished leather ready for garment making | Any | β Yes (Finished/Coated) |
4105.10.00.00 |
Sheep/Lamb skins, tanned | Fur lining, small leather goods | Chrome/Veg | β No |
4106.21.00.00 |
Goat/Skidskin, tanned | Luxury accessories | Chrome/Veg | β No |
π Critical Reminder:
- 4107.19.60.10 is strictly for unfinished or lightly finished leather. If you have dyed, pigmented, or embossed leather, do NOT use this code. It must be classified under 4104. - Misclassification can lead to underpayment of duties (if 4104 has higher rates) or rejection by customs.
π° III. 2026 Latest Tariff Rate Details (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: November 10, 2025 onwards
π― 1. 4107.19.60.10 ββ Full Grain Cow Leather (Unfinished/Chrome Tanned)
| Item | Content |
|---|---|
| Base MFN Rate | 4.8% (ad valorem) |
| Section 301 Tariff (USITC) | +7.5% (Footnote 9903.88.01 applies to many leather goods, but check specific footnote for raw hides; often 0% for raw hides, but leather skins may be subject to 7.5% or higher depending on exact subheading interpretation). Note: Many raw hides are 0% under 301, but finished leathers are not. However, 4107 is often considered "semi-processed". Update: Under recent 301 reviews, many leather articles are subject to 7.5% or 25%. Assume 7.5% for safety unless ruling confirms 0%. |
| IEEPA Surcharge | +10% (Specific to China-origin goods under recent executive orders) |
| Total Rate | ~12.3% (Base 4.8% + 7.5% 301 + 10% IEEPA = 22.3%) (Note: If 301 applies 0% to raw hides, total is 14.8%. If 301 applies 7.5%, total is 22.3%.) |
| Tax Calculation | CIF Value Γ Total Rate |
| De Minimis Eligibility | β No (deny_de_minimis) |
| Legal Path | USITC:4107.19.60.10 β FOOTNOTE:9903.88.01 β IEEPA:9903.01.24 |
π Explanation:
- Base Rate (4.8%): Standard MFN rate for tanned leather. - Section 301: Raw hides (Chapter 41) often have 0% or 7.5% under 301. Critical: Check if the leather is considered "unfinished." If yes, 0% may apply. If "semi-finished," 7.5%. Conservative Estimate: 7.5%. - IEEPA 10%: New surcharge for Chinese-origin goods. - Total: 12.3% β 22.3%. Do not assume 0%.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Required Documents Checklist (Non-Negotiable)
| Document | Must Provide | Explanation |
|---|---|---|
| β Leather Certificate | βοΈ | Must specify: "Full Grain," "Chrome Tanned," "Not Further Finished." |
| β Tanning Process Description | βοΈ | Detail tanning method (Chrome vs. Vegetable), dyeing process (if any), and finish level. |
| β Physical Samples | βοΈ | Customs may require a sample to verify "full grain" vs. "corrected grain." |
| β Commercial Invoice | βοΈ | Clearly state "Raw/Unfinished Leather for Further Manufacturing," NOT "Finished Leather Goods." |
| β Packing List | βοΈ | Specify weight, area (sq. ft/mΒ²), and hide count. |
| β FDA/Environmental Compliance | βοΈ | If chrome-laden, ensure compliance with EPA regulations. |
β 2. Declaration Tips (Key Mnemonics)
π₯ "Unfinished, Chrome, Full Grain = 4107. Finished, Dyed, Embossed = 4104!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Raw leather, just tanned | 4107.19.60.10 |
Declared as "Fabric" β Seizure! |
| Leather dyed blue and coated | 4104.19.00.00 |
Declared as 4107 β Underpayment Penalty! |
| Split leather (suede backing) | 4107.19.60.10 |
Declared as "Sheepskin" β Misclassification |
| Leather accessories (bags) | 4202.12.00.00 |
Declared as raw leather β Major Fraud! |
β 3. Special Cases Handling
| Scenario | Handling Advice |
|---|---|
| Mixed Hides (Cow + Sheep) | Declare separately. Do not combine. |
| Leather with Metal Hardware | If hardware is embedded and integral, may shift to Chapter 42. Keep hardware minimal or declare as accessories. |
| Organic/Vegetable Tanned | May qualify for lower 301 tariffs in some interpretations. Provide tanning agent proof. |
| Recycled Leather | Not covered under 4107. May fall under 3917 or 6310. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification Required | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 4107.19.60.10 |
~12.3% - 22.3% | FDA (if food contact) | High scrutiny on "finished" status |
| π¨π³ China | 4107.19.60.10 |
0% (Imported) | N/A | China is a major exporter, not importer |
| πͺπΊ EU | 4107.19.60.10 |
3.2% | REACH (Chrome VI limit) | Strict Chrome VI limits (3ppm) |
| π¬π§ UK | 4107.19.60.10 |
3.2% | UKCA (if applicable) | Post-Brexit rules apply |
| π―π΅ Japan | 4107.19.60.10 |
0% | FSC (if chemical treatment) | Free trade under JTEPA |
π Conclusion:
- USA has the highest effective duty due to IEEPA and 301 tariffs.
- EU is strict on Chrome VI content. Ensure lab tests are available.
- Japan offers favorable terms.
π VI. Common Mistakes & Pitfalls (Blood Lessons)
β Mistake 1: Declaring "Finished Leather Goods" (e.g., bags) as raw leather (4107)
π Consequence: Seizure, fines, and loss of import privileges.
β Mistake 2: Not providing a Tanning Certificate
π Consequence: Customs cannot verify if itβs "unfinished." Hold for inspection.
β Mistake 3: Confusing "Full Grain" with "Genuine Leather"
π Consequence: "Genuine Leather" is a marketing term, not an HS code. Must specify tanning method and finish level.
β Mistake 4: Ignoring Chrome VI Regulations
π Consequence: EU/US recall if Chrome VI > 3ppm. Fine up to 20% of CIF value.
β Correct Practice:
"Full Grain Cowhide, Chrome Tanned, Unfinished, Not Further Dyed or Coated, for Use in Manufacturing Handbags. Certificate of Analysis Attached."
π― VII. Conclusion: Professional Declaration, Save Costs!
π― Remember Mnemonic:
πΉ "4107 for Raw, 4104 for Finished. Donβt Mix Them!"
πΉ "Chrome Tanned, Check VI. Finish Level Determines Duty!"
π Tips:
- If your leather is vegetable-tanned, it may have lower 301 tariffs in some cases. Provide proof.
- Consider applying for a Customs Ruling before shipment to confirm classification.
- For high-volume imports, negotiate FOB terms to shift duty burden negotiation.
π£ Immediate Action:
π Contact your customs broker with Tanning Certificate + Chrome VI Test Report.
π Ensure your invoice clearly states "Unfinished Leather for Further Processing."
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every percentage point of duty matters!
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.