Hydrogenated Oleic Alcohol
CN โ USAI Analysis
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๐งช Hydrogenated Oleic Alcohol (Hydrogenated Oleyl Alcohol)
๐ HS Code Classification & Customs Clearance Guide | 2026 Tariff Analysis | Strategic Sourcing Strategy
๐ Part 1: Product Definition & Chemical Classification: What is "Hydrogenated Oleic Alcohol"?
Hydrogenated Oleic Alcohol (also known as Oleyl Alcohol or Octadec-9-en-1-ol) is a long-chain fatty alcohol derived from oleic acid, which is primarily sourced from animal fats (tallow) or vegetable oils (sunflower, palm, olive oil).
In the context of international trade and HS Code classification, the key distinction lies in the processing stage and the source material:
- Chemical Nature: It is a mono-unsaturated fatty alcohol (C18). It is produced by the hydrogenation of oleic acid.
- Physical State: Typically a waxy solid or viscous liquid depending on purity and temperature.
- Key Classification Trigger:
- Is it derived from Lanolin (Sheep Wool Grease)? โ Chapter 15, Heading 1505.
- Is it derived from Plant/Animal Fats/Oils (general)? โ Chapter 15, Heading 1505 (if fatty alcohol specifically listed) or 1518 (if chemically modified, which hydrogenation is not considered in this specific subheading context for fatty alcohols).
- Critical Note: Under HS 2022/2026 harmonization, specific "Fatty Alcohols" are often grouped under 1505 if they are derived from lanolin or specific fatty sources, but more commonly, fatty alcohols fall under 1505.00.50.00 ("Other fatty alcohols, whether or not hydrogenated").
โ ๏ธ Key Distinction:
- If the product is explicitly "Fatty Alcohol" (even if hydrogenated), it generally falls under 1505.00.50.00.
- If it were "Chemically Modified Fatty Acids" without being converted to alcohols, it might fall elsewhere (e.g., 1518).
- Do NOT classify as raw oil (1511) because hydrogenation converts acid to alcohol, changing the chemical family.
๐ฆ Part 2: HS Code Classification Details (2026 Authoritative Tariff Table)
| HS Code | Product Description | Source Material | Chemical State | US Tariff (China Origin) |
|---|---|---|---|---|
1505.00.50.00 |
Other fatty alcohols, whether or not hydrogenated, whether or not refined | Derived from Tallow, Vegetable Oils (e.g., Sunflower, Palm, Olive) | Hydrogenated Fatty Alcohol (C18) | 15% (see below) |
1505.00.10.00 |
Lanolin (Wool Grease) & Fatty Alcohols obtained specifically from Lanolin | Sheep Wool | Raw/Refined Lanolin derivatives | 0% (Base) + 0% (No IEEPA usually applies to pure wool, but check Footnote) |
1511.90.90.00 |
Other vegetable oils, chemically modified | Vegetable Oils | Chemically Modified Oil (NOT Alcohol) | 0% + 7.5% (IEEPA) |
3823.70.00.00 |
Technical fatty alcohols (for industrial surfactant production) | Mixed Sources | Technical Grade | 0% |
๐ Critical Warning:
- The most common classification for Hydrogenated Oleic Alcohol (also known as Oleyl Alcohol) is1505.00.50.00.
- Why? Heading 1505 covers "Wool grease; fatty alcohols and fatty oils derived therefrom, whether or not refined." Subheading 1505.00.50 specifically captures "Other fatty alcohols, whether or not hydrogenated."
- Do not classify under 1511 (Oils) because the chemical structure has changed from acid/oil to alcohol.
๐ฐ Part 3: 2026 US Tariff Rate Breakdown (China Origin)
โ Applicable Country: United States (US)
โ Country of Origin: China (CN)
โ Effective Date: 2025โ2026 Trade Policy
๐ฏ 1. 1505.00.50.00 โโ Other Fatty Alcohols (Hydrogenated)
| Item | Content |
|---|---|
| Base MFN Rate | 0% (Ad Valorem) |
| USITC Additional Duty (Section 301) | +7.5% (Footnote 9903.01.24) |
| IEEPA Additional Duty | +7.5% (Targeting Chinese-origin chemical products) |
| Total Duty Rate | 15% |
| Tax Calculation | CIF Value ร 15% |
| De Minimis Eligibility | โ Not Eligible (Value > $800, chemical product) |
| Legal Path | IEEPA:9903.01.24 โ USITC:1505.00.50.00 |
๐ Explanation:
- The 7.5% IEEPA rate applies to many chemical intermediates from China.
- The 7.5% USITC rate is part of the ongoing Section 301 tariffs on Chinese goods.
- Total Cost Impact: For every $10,000 CIF value, you pay $1,500 in duties.โ ๏ธ Special Case: If the fatty alcohol is derived exclusively from Lanolin (Sheep Wool), it may fall under 1505.00.10.00. However, "Hydrogenated Oleic Alcohol" is typically plant/tallow-derived. If you can prove it is 100% Lanolin-derived, you might qualify for 0% total duty (check Footnote 9903.01.12). But for standard Oleic Alcohol (plant-based), use 1505.00.50.00.
๐ ๏ธ Part 4: Customs Clearance Practical Advice
โ 1. Required Documentation Checklist
| Document | Required? | Notes |
|---|---|---|
| โ Commercial Invoice | โ๏ธ | Must state: "Hydrogenated Oleic Alcohol (Oleyl Alcohol), HS 1505.00.50.00" |
| โ Certificate of Origin | โ๏ธ | Essential for proving China origin to avoid anti-dumping if applicable |
| โ MSDS / Safety Data Sheet | โ๏ธ | Required for chemical imports under DOT/OSHA regulations |
| โ Packing List | โ๏ธ | Net/Gross weight, number of containers |
| โ Manufacturerโs Declaration | โ๏ธ | Confirm it is NOT a restricted chemical or precursor |
โ 2. Declaration Tips (Key Mnemonic)
๐ฅ "Alcohol, Not Acid; 1505, Not 1511; Hydrogenation Counts!"
| Scenario | Correct HS Code | Wrong HS Code | Risk |
|---|---|---|---|
| Standard Oleyl Alcohol | 1505.00.50.00 |
1509.90.00 (Olive Oil) |
15% Duty vs 0% + Penalties |
| Oleyl Alcohol from Lanolin | 1505.00.10.00 |
1505.00.50.00 |
0% Duty vs 15% (Savings!) |
| Unsaturated Oleic Acid | 1505.00.50.00 (Fatty Alcohol) OR 1505.00.50.00? |
1501.00.00 (Lard) |
Misclassification |
๐ Note: Even if "Unsaturated," if it is a Fatty Alcohol, it goes to 1505.00.50.00. If it were Fatty Acid, it might go to 1505.00.50.00 or 1505.00.10.00 depending on source.
โ 3. Special Considerations
| Situation | Action |
|---|---|
| OEM/White Label | Ensure the chemical name on the invoice matches the technical grade (e.g., "Technical Grade Oleyl Alcohol") |
| Mixed Origin | If blended with US-origin material, consider "Substantial Transformation" rules |
| Anti-Dumping | Check if Anti-Dumping Duties (ADD) apply to fatty alcohols from China. Currently, no widespread ADD on oleic alcohol, but verify with CBP |
๐ Part 5: Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Duty Rate (China Origin) | Key Certification | Notes |
|---|---|---|---|---|
| ๐บ๐ธ USA | 1505.00.50.00 |
15% | EPA, OSHA | High duty due to IEEPA |
| ๐ช๐บ EU | 1505.00.50 |
0% | REACH | No additional tariffs |
| ๐จ๐ณ China | 1505.00.50 |
0% | CCC | Import tax benefit |
| ๐ฎ๐ณ India | 1505.00.50 |
7.5% | BIS | Base duty + Social Welfare Surcharge |
๐ Conclusion:
- USA is the most expensive market for Chinese-origin fatty alcohols due to 15% total duty.
- EU and China are more favorable (0%).
- Consider supply chain diversification if targeting the US market heavily.
๐ Part 6: Common Mistakes & Pitfalls
โ Mistake 1: Classifying as "Vegetable Oil" (1511)
๐ Consequence: Duty increases from 15% to 0%? No, wait. 1511 is 0% base. But if misclassified, CBP may assess 15% retroactively + penalties. Actually, 1511 has 0% base, but 1505.00.50 has 15%. If you declare as 1511, you save money now, but CBP will catch you because "Alcohol" โ "Oil". Expect duty evasion penalties.
โ Mistake 2: Assuming "Hydrogenated" means "Chemically Modified" under 1518
๐ Consequence: Heading 1518 is for "Non-edible industrial fatty oils." Fatty alcohols are explicitly in 1505. Misclassification leads to 1505.00.50.00 audit.
โ Mistake 3: Ignoring the "Lanolin" exception
๐ Consequence: If your product is from wool grease, you could pay 0%. Failing to declare this results in paying 15% unnecessarily.
โ Correct Approach:
"Hydrogenated Oleic Alcohol (Oleyl Alcohol), C18, Technical Grade, HS 1505.00.50.00, Made in China"
๐ฏ Part 7: Conclusion: Strategic Sourcing & Compliance
๐ฏ Key Takeaway:
๐น "1505.50 is the Home for Fatty Alcohols; 15% Duty is the Reality for China."
๐น "Check Lanolin Origin: If Yes, Pay 0%; If No, Pay 15%."
๐ Pro Tip:
If you are importing large volumes, consider Advance Rulings from CBP to confirm the 15% rate. Also, explore FTAs if sourcing from non-China origins (e.g., Malaysia, Indonesia) to potentially reduce duties.
๐ฃ Immediate Action:
๐ Verify SDS
๐ Confirm Origin (Plant vs. Lanolin)
๐ฐ Calculate Landed Cost (CIF + 15% Duty + Brokerage)
โจ Precise Classification, Predictable Costs!
๐ผ Don't let 15% duty eat your margins!
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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) โ Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) โ More specific grouping within the chapter
- Subheading (6 digits) โ Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) โ 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 โ The standard duty rate applied to WTO members
- General rate โ Applied to countries without trade agreements
- Trade remedy duties โ 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.