High Performance Rubber Radial Tires
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 4012194000 | 39.0% | CN | US | Official Doc |
| 4016996010 | 37.5% | CN | US | Official Doc |
| 4012909000 | 37.7% | CN | US | Official Doc |
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AI Analysis
π High Performance Rubber Radial Tires (Regenerated Rubber)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy
π I. Product Definition & Classification: What Exactly Are "High Performance Regenerated Rubber Radial Tires"?
High performance tires, specifically those made from regenerated rubber and featuring a radial (sub-line) structure, are specialized automotive components. In international trade, they do not have a single direct classification. Instead, they fall into a narrow band of HS Codes under Chapter 40 (Rubber and articles thereof).
The core dispute lies in whether they are classified as "Retreaded Tires" (Class 4012.19) or "Other Rubber Articles/Tires" (Class 4016.99/4012.90). The material "Regenerated Rubber" is the key differentiator, linking it to specific sub-headings.
β οΈ Key Distinction Points: - Material: "Regenerated Rubber" (reclaimed) falls under "Rubber" in Chapter 40. - Structure: "Radial" (Sub-line) tires are specifically targeted in heading 4012.19. - Form: If considered "Retreaded/Reconditioned," they fit 4012.19. If considered "New but made of regenerated rubber," they may fall into 4016.99 or 4012.90.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the product characteristics ("Regenerated Rubber," "Radial Tire"), the following three HS Codes are the primary candidates. Note: All these codes are subject to heavy additional tariffs due to US-China trade tensions.
| HS Code | Product Description | Matching Logic (Why it fits) | Total Tax Rate |
|---|---|---|---|
4012.19.40.00 |
Retreaded or used pneumatic tires of rubber (Specifically Radial/Sub-line) |
Exact Match: 1. "Radial Tire" corresponds to "Radial Tires" (Sub-line). 2. "Regenerated Rubber" corresponds to "Retreaded/Reconditioned" rubber characteristics. 3. Material and form fully comply. |
39.0% |
4016.99.60.10 |
Other articles of vulcanized rubber other than hard rubber (Specific to Tire-like parts) |
Logical Inference: 1. "Regenerated Rubber" falls under the scope of "Vulcanized Rubber" (4016.99). 2. Form is "Tire," a vulcanized rubber article. 3. Inferred as automotive mechanical part/rubber article. |
37.5% |
4012.90.90.00 |
Other pneumatic tires of rubber, new (Other tires) |
Broad Match: 1. Material "Regenerated Rubber" and Form "Tire" fit the category. 2. Belongs to specific categories under thisη»ε item. 3. Considered a "Rubber-made" tire category. |
37.7% |
π Key Reminder: -
4012.19.40.00is the most precise match for "Radial + Regenerated/Retreaded" logic, but carries the highest base tax rate among the three due to specific footnote allocations. -4016.99.60.10and4012.90.90.00are alternative classifications if the "Retreaded" nature is disputed, but still carry high tariffs. - Do not classify as new passenger car tires (e.g., 4011.10) as the material "Regenerated Rubber" excludes them from standard new tire categories.
π° III. 2026 Latest Tariff Rate Breakdown (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: November 10, 2025 (and subsequent imports)
All three HS Codes above are subject to the same surtax structure under Section 301 and IEEPA regulations.
π― 1. 4012.19.40.00 ββ Retreaded/Used Radial Tires (Regenerated Rubber)
| Item | Content |
|---|---|
| Base Tariff | 4.0% (Standard MFN rate for heading 4012.19) |
| Section 301 Surtax | +25.0% (China-specific additional duty) |
| Section 122 / IEEPA | +10.0% (Additional duty under IEEPA for certain Chinese goods) |
| Total Tax Rate | 39.0% |
| Tax Calculation | CIF Value Γ 39.0% |
| De Minimis Exemption? | β NO (deny_de_minimis) β Strictly prohibited. |
| Legal Path | IEEPA:9903.01.25 β USITC:4012.19.40.00 β FOOTNOTE:301 |
π Explanation: - "Section 301 25%": The standard punitive tariff for Chinese rubber articles. - "IEEPA 10%": Additional surcharge targeting specific Chinese industrial materials. - "Total 39%": This is a very high cost. Must be calculated in advance! - "Regenerated Rubber" Risk: Customs may scrutinize whether the product is truly "Retreaded" (4012) or "New but made of reclaimed rubber" (4016/4012.90). Misclassification can lead to penalties.
π― 2. 4016.99.60.10 ββ Other Vulcanized Rubber Articles (Tire-like)
| Item | Content |
|---|---|
| Base Tariff | 2.5% (Standard MFN rate for heading 4016.99) |
| Section 301 Surtax | +25.0% |
| Section 122 / IEEPA | +10.0% |
| Total Tax Rate | 37.5% |
| Tax Calculation | CIF Value Γ 37.5% |
| De Minimis Exemption? | β NO (deny_de_minimis) |
| Legal Path | IEEPA:9903.01.24 β USITC:4016.99.60.10 β FOOTNOTE:301 |
π Note: - Slightly lower total tax (37.5% vs 39.0%) due to a lower base rate (2.5% vs 4.0%). - However, the classification argument is weaker: Is a "Regenerated Rubber Tire" really an "Other Rubber Article" (4016) rather than a "Tire" (4012)? Customs may challenge this.
π― 3. 4012.90.90.00 ββ Other Rubber Tires (New/Other)
| Item | Content |
|---|---|
| Base Tariff | 2.7% (Standard MFN rate for heading 4012.90) |
| Section 301 Surtax | +25.0% |
| Section 122 / IEEPA | +10.0% |
| Total Tax Rate | 37.7% |
| Tax Calculation | CIF Value Γ 37.7% |
| De Minimis Exemption? | β NO (deny_de_minimis) |
| Legal Path | IEEPA:9903.01.24 β USITC:4012.90.90.00 β FOOTNOTE:301 |
π Note: - Total tax 37.7%. - This code is for "Other" tires. If your product is explicitly "Radial" and "Regenerated/Retreaded," 4012.19.40.00 is more accurate despite the higher tax. If classified here, you must prove it does not fit 4012.19.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Required Documentation Checklist (Non-negotiable)
| Document | Must Provide | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must explicitly state: "Material: Regenerated Rubber," "Structure: Radial," "Application: High Performance." |
| β Certificate of Composition | βοΈ | Lab report confirming the percentage of "Regenerated Rubber" vs. Natural/Synthetic. |
| β Product Photos (Markings) | βοΈ | Clear shots of sidewall markings (e.g., "RADIAL," "RECLAIMED," Model Number). |
| β Commercial Invoice | βοΈ | Must NOT use vague terms like "Tires." Use precise description: "High Performance Radial Tire, Regenerated Rubber." |
| β Bill of Lading / Packing List | βοΈ | Consistent with invoice. |
| β ISF (Importer Security Filing) | βοΈ | Submit 24 hours before loading in China. Critical for timely release. |
β 2. Declaration Tips (Key Mantra)
π₯ "Material First, Structure Second, Code Precise, Tax Avoids Disaster!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Explicitly Retreaded/Reclaimed | 4012.19.40.00Desc: "Radial Tire, Retreaded/Regenerated Rubber" |
Misdeclare as "New Tire" β 25%+ penalty + Back Tax |
| New Tire made of Regenerated Rubber | 4012.90.90.00 or 4016.99.60.10Desc: "New Radial Tire, Material: Regenerated Rubber" |
Use 4011.10 (Passenger Tire) β Wrong Code, Seizure Risk |
| Mixed Shipment (New + Retreaded) | Split Declaration Code separately by type |
Mix together β Customs Rejection / Inspection Hold |
| OEM/Contract Manufacturing | Provide Client Order + Design Specs | Vague "For Auto Parts" β Delay in Release |
β 3. Special Case Handling
| Case | Handling Advice |
|---|---|
| High Risk of "Regenerated" Dispute | Provide third-party lab test reports proving the rubber content. If Customs suspects it's actually "New" but labeled "Regenerated" to avoid tariffs, they will reclassify and penalize. |
| Tire Tread Depth | If "Retreaded," tread depth is a key indicator. Provide photos showing re-treading marks. |
| Origin Marking | Ensure tires are marked "Made in China." Failure to mark leads to fines. |
| ISF Penalty | Late ISF filing for rubber tires is common. File early! |
π V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (CN Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 4012.19.40.004016.99.60.104012.90.90.00 |
37.5% - 39.0% | DOT (Safety), EPA (if applicable) | Highest Tariffs Globally. Section 301 applies. |
| π¨π³ China | 4012.19.40.00 |
4.0% | CCC (if applicable) | No additional surtaxes. |
| πͺπΊ EU | 4012.19.40.00 |
0% - 3% | E-Mark (ECE Regulation) | No Section 301. Check anti-dumping if any. |
| π¦πΊ Australia | 4012.19.40.00 |
5.0% | ARBI Approval | No surtaxes. |
| π―π΅ Japan | 4012.19.40.00 |
0% - 5% | JIS / PSC | No surtaxes. |
π Conclusion: - The USA is the ONLY market with punitive tariffs on these goods. - Cost Impact: A $10,000 shipment to the US will face $3,750 - $3,900 in duties alone. - Strategy: If targeting the US, ensure your supplier is not using Chinese origin if possible, or factor this cost into pricing. Vietnam/Mexico origin may have lower duties (check FTAs), but "Regenerated Rubber" origin rules are strict.
π VI. Common Mistakes & Pitfalls (Blood & Tears Lessons)
β Mistake 1: Classifying "Regenerated Rubber Tires" as "New Passenger Car Tires" (4011.10)
π Consequence: Customs reclassifies to 4012.19.40.00 β Back taxes + 10% penalty + Seizure risk.
β Mistake 2: Using "Tires" as the only description on the Invoice
π Consequence: Customs cannot determine if it's Radial or Bias, New or Retreaded β Inspection Delay (1-4 weeks).
β Mistake 3: Ignoring the "Regenerated" aspect
π Consequence: If the product is actually "New" but made from reclaimed rubber, declaring it as "Retreaded" (4012.19) is fraud. If declared as "New" (4011), itβs wrong material. Correct is 4012.90 or 4016.99.
β Mistake 4: Late ISF Filing
π Consequence: $5,000 per violation penalty for late/incorrect ISF.
β Correct Approach:
"High Performance Radial Tire, Regenerated Rubber, Retreaded/New [Specify], DOT Approved, Model XYZ, HS Code: 4012.19.40.00"
π― VII. Conclusion: Precise Classification Saves Millions!
π― Remember the Mantra:
πΉ "Regenerated Rubber = 4012/4016, NOT 4011!"
πΉ "Radial Structure = 4012.19, NOT 4012.90!"
πΉ "US Import = 39% Tax, Plan Budget Accordingly!"
π Pro Tip:
- If your product is 100% Regenerated Rubber and Radial,
4012.19.40.00is the most defensible classification.- Apply for a Pre-Ruling (Advance Ruling) from US Customs (CBP) before shipment to lock in the HS Code and avoid surprises.
- Document Everything: Keep lab reports and material safety data sheets (MSDS) ready for inspection.
π£ Immediate Action:
π Contact your Freight Forwarder + Provide Product Specs + Request CBP Pre-Ruling
π Clear Customs Smoothly, Avoid Penalties, Protect Your Margins!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Your Every Dollar of Duty is Worth Calculating Precisely!
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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) 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.