Industrial Chemical Products (HS 3402501100)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3402501100 | 39.0% | CN | US | Official Doc |
| 3910000000 | 38.0% | CN | US | Official Doc |
| 3402505100 | 35.0% | CN | US | Official Doc |
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π§ͺ Industrial Chemical Products & Silicone Forms (HS 3402 / 3910)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
π I. Product Definition & Classification: What Exactly Are We Importing?
In international trade, "Industrial Chemical Products" and "Silicones" are distinct categories often confused due to their similar applications in manufacturing, lubrication, and surface treatment. Precise classification is critical because the tariff rates differ significantly between raw silicone forms and finished surface-active preparations.
These products generally fall into two main chapters: 1. Chapter 39: Plastics and Articles Thereof β Specifically for Silicones in primary forms (raw, unprocessed silicones). 2. Chapter 34: Soap, Organic Surface-Active Agents, Washing Preparations... β Specifically for Surface-active preparations (formulated chemicals, detergents, or additives).
β οΈ Key Distinction Point:
- If the product is a raw silicone polymer (liquid, paste, or solid silicone oil/gel) intended for further processing into rubber or sealants β It belongs to HS 3910.00.00.00.
- If the product is a formulated chemical mixture (e.g., wetting agents, emulsifiers, or cleaning additives) containing aromatic agents or put up for retail/specific industrial use β It belongs to HS 3402.50.11.00 or HS 3402.50.51.00.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Cross-Reference)
| HS Code | Product Description | Application Scenario | Tariff Structure |
|---|---|---|---|
3910.00.00.00 |
Silicones in primary forms | Raw silicone oils, greases, resins, or polymers used as base materials for rubber, sealants, or coatings. | π Base: 3.0% π Additional: 25.0% π° Total: 28.0% |
3402.50.11.00 |
Organic surface-active agents; preparations containing any aromatic or modified aromatic surface-active agent | Specialized industrial additives, wetting agents, or emulsifiers that contain aromatic compounds. Often used in textile, paper, or coating industries. | π Base: 4.0% π Additional: 25.0% π° Total: 29.0% |
3402.50.51.00 |
Other surface-active preparations (put up for retail sale) | Cleaning preparations, auxiliary washing agents, or surface-active mixes put up for retail sale, excluding those with aromatic agents. | π Base: 0.0% π Additional: 25.0% π° Total: 25.0% |
π Important Note:
- HS 3402.50.11.00 and HS 3402.50.51.00 are both "Surface-active preparations," but the key differentiator is the presence of aromatic agents. If your product contains aromatic surface-active agents, it must go to3402.50.11.00(29% tax).
- HS 3910.00.00.00 is strictly for Silicones. Do not misclassify silicone-based cleaning agents as "Silicones in primary forms." If itβs a formulated cleaner, it likely falls under Chapter 34.
π° III. 2026 Latest Tariff Rate Breakdown (Detailed Tax Clauses)
β Applicable Market: USA (US)
β Origin: China (CN)
β Effective Date: Current trade policies apply (2025-2026)
π― 1. 3910.00.00.00 ββ Silicones in Primary Forms
| Item | Detail |
|---|---|
| Base Tariff | 3.0% (General rate for Chapter 39 plastics/silicones) |
| Additional Tariff (Section 301) | +25.0% (Specific to Chinese origin silicones and related chemical products) |
| Total Tax Rate | 28.0% |
| Tax Calculation | CIF Value Γ 28.0% |
| De Minimis Eligibility | β Not Eligible (De minimis rules generally exclude goods subject to Section 301 tariffs) |
| Legal Basis Path | HTSUS:3910.00.00.00 β USITC Footnote 9903.88.01 (Section 301 Additional Duties) |
π Explanation:
- Silicones are considered strategic industrial materials. The 25% additional duty is strictly enforced under Section 301 of the Trade Act.
- Even if the silicone is used as a raw material for manufacturing, the 28% total duty applies at the point of import.
- Cost Impact: This is a high-cost category. Suppliers often need to adjust pricing or explore duty exemption programs (e.g., U.S. Manufacturing Competitive Inventory).
π― 2. 3402.50.11.00 ββ Organic Surface-Active Agents (With Aromatic Agents)
| Item | Detail |
|---|---|
| Base Tariff | 4.0% (Standard rate for surface-active preparations) |
| Additional Tariff (Section 301) | +25.0% (Applied to specific chemical preparations from China) |
| Total Tax Rate | 29.0% |
| Tax Calculation | CIF Value Γ 29.0% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | HTSUS:3402.50.11.00 β USITC Footnote 9903.88.01 |
π Explanation:
- The presence of "aromatic or modified aromatic surface-active agent" triggers this specific subheading.
- Higher Risk: Customs may require a Material Safety Data Sheet (MSDS) and a detailed composition list to verify the presence of aromatic compounds.
- Cost Impact: 29% is the highest tax rate among the listed codes. Accurate ingredient disclosure is vital to avoid penalties for misclassification.
π― 3. 3402.50.51.00 ββ Other Surface-Active Preparations (Retail, Non-Aromatic)
| Item | Detail |
|---|---|
| Base Tariff | 0.0% (Preferential or zero-rate for certain non-aromatic cleaning aids) |
| Additional Tariff (Section 301) | +25.0% (Section 301 still applies) |
| Total Tax Rate | 25.0% |
| Tax Calculation | CIF Value Γ 25.0% |
| De Minimis Eligibility | β Not Eligible |
| Legal Basis Path | HTSUS:3402.50.51.00 β USITC Footnote 9903.88.01 |
π Explanation:
- This is the lowest tax rate among the chemical categories listed.
- Key Condition: The product must NOT contain aromatic surface-active agents. If it does, it must be reclassified to3402.50.11.00(29%).
- Optimization Tip: If your product formulation allows, removing aromatic agents could potentially save 4% in taxes (29% vs. 25%), provided it still meets the technical requirements for3402.50.51.00.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Must Provide | Purpose |
|---|---|---|
| β MSDS / SDS | βοΈ | Mandatory for all chemical imports. Must specify exact chemical composition, including presence/absence of aromatic agents. |
| β Product Specification Sheet | βοΈ | Details viscosity, pH, density, and intended use (industrial vs. retail). |
| β Commercial Invoice | βοΈ | Must clearly state: "Silicones in Primary Forms" OR "Surface-Active Preparation." No generic terms like "Chemical Mix." |
| β Certificate of Origin | βοΈ | Required to verify Chinese origin for Section 301 applicability. |
| β EPA Registration (if applicable) | βοΈ | If the product is classified as a cleaning agent or antimicrobial, EPA approval may be required before customs release. |
β 2. Declaration Tips (Critical Mnemonics)
π₯ "Silicones are 39, Chemicals are 34. Aromatics mean 29, No aromatics mean 25."
| Scenario | Correct HS Code | Error Consequence |
|---|---|---|
| Raw Silicone Oil/Resin | 3910.00.00.00 (28%) |
Misclassified as chemical β Audit + Back Taxes |
| Detergent with Benzene Derivatives | 3402.50.11.00 (29%) |
Misclassified as non-aromatic β Underpayment + Penalties |
| Retail Cleaning Spray (No Aromatics) | 3402.50.51.00 (25%) |
Misclassified as aromatic β Overpayment (minor but inefficient) |
β 3. Special Situation Handling
| Situation | Handling Advice |
|---|---|
| Blend of Silicone + Surfactant | If the product is a formulated mixture, it is likely a "Surface-Active Preparation" (Chapter 34), not "Silicones in Primary Forms" (Chapter 39). Do not declare as 3910. |
| Retail vs. Industrial Packing | If put up for retail sale, it falls under 3402.50.5x or 3402.50.1x. Bulk industrial containers may still fall under Chapter 34 if they are formulations. |
| Aromatic Content Uncertainty | If unsure if the product contains aromatic agents, assume it does and classify under 3402.50.11.00. Misclassification can lead to severe penalties. |
| Section 301 Exclusion List | Check the latest USTR Exclusion List. Some specific chemical products may be excluded from the 25% additional duty. Apply for exclusion if eligible. |
π V. Global Market Comparison (2026 Snapshot)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Key Requirement | Note |
|---|---|---|---|---|
| πΊπΈ USA | 3910 / 3402 |
25%β29% | Section 301 Applies | High duty environment. Exclusions possible. |
| π¨π³ China | 3910 / 3402 |
Low/Zero | None | Domestic trade has no tariffs. |
| πͺπΊ EU | 3910 / 3402 |
0%β6.5% | REACH Compliance | No Section 301. REACH registration is mandatory for chemicals. |
| π¬π§ UK | 3910 / 3402 |
0%β6.5% | UK REACH | Post-Brexit rules mirror EU but require separate registration. |
| π―π΅ Japan | 3910 / 3402 |
0%β5.0% | JITL/JIS | Low tariffs. Focus on quality certification. |
π Conclusion:
- USA is the most challenging market due to Section 301 tariffs.
- EU/UK/Japan are more tariff-friendly but have strict chemical registration (REACH, UK REACH, JITL) requirements.
- Optimization Strategy: For US imports, explore Section 301 Exclusions or consider supply chain diversification if volumes are high.
π VI. Common Errors & Pitfall Guide (Lessons Learned)
β Error 1: Classifying a formulated silicone cleaner as 3910.00.00.00 (Silicones in Primary Forms).
π Consequence: Customs will reject it. Silicones in primary forms must be unprocessed. Formulated products go to Chapter 34. Risk: Seizure/Return.
β Error 2: Ignoring the "Aromatic Agent" clause in 3402.50.11.00.
π Consequence: If your product contains aromatic surfactants, declaring it as 3402.50.51.00 (25%) instead of 3402.50.11.00 (29%) is smuggling. Risk: Heavy Fines + Criminal Liability.
β Error 3: Assuming De Minimis applies to chemical imports.
π Consequence: Section 301 tariffs override de minimis exemptions for goods from China. Risk: Duty evasion detection.
β Error 4: Submitting incomplete MSDS.
π Consequence: Customs cannot verify the presence of aromatic agents. Risk: Delays + Additional Lab Testing Costs.
β Correct Approach:
"Surface-Active Preparation, Industrial Grade, Contains Aromatic Agents, Bulk Container, MSDS Attached, Section 301 Applicable."
π― VII. Conclusion: Precision Classification Saves Money!
π― Remember the Mnemonic:
πΉ "Silicones are 39 (28%), Chemicals are 34."
πΉ "Aromatics mean 29%, No Aromatics mean 25%."
πΉ "No De Minimis for Section 301!"
π Pro Tip:
If your product is a blend of silicone and surfactant, consult a customs broker or laboratory to determine the Essential Character. If the silicone is the primary component, it might still be classified under Chapter 39. If the surfactant determines the function, it falls under Chapter 34.
π£ Immediate Action:
π Contact a Licensed Customs Broker
π Provide Full MSDS & Product Formula
π Apply for HS Code Ruling if Value is High
π Optimize Your Supply Chain to Mitigate 25β29% Tariffs!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Your Profit Margin Depends on Your HS Code!
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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.