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Low Carbon Alcohol Mixture

CN β†’ US
HS Code Tariff Rate Origin Destination Doc
2905199010 38.7% CN US Official Doc
3824999330 40.0% CN US Official Doc
2905199090 38.7% CN US Official Doc
3824999310 40.0% CN US Official Doc

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πŸ§ͺ Low Carbon Alcohol Mixture


🌐 HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
πŸ“Œ I. Product Definition & Classification: Do You Really Understand "Low Carbon Alcohol"?

"Low Carbon Alcohol Mixture" typically refers to a blend of saturated monohydric alcohols with low carbon chain lengths (often C1 to C11). In international trade, this ambiguous name can lead to two distinct classification paths depending on whether the product is viewed as a chemical substance or a chemical mixture/preparation.

Key Distinction:
- Chemical Substance Category (Chapter 29): If the mixture consists primarily of specific saturated alcohols (e.g., methanol, ethanol, propanol) and is defined by its chemical identity rather than a specific industrial function, it may fall under 2905.
- Chemical Mixture Category (Chapter 38): If the product is a complex blend, has no specific chemical name, or is classified as a "preparation" where the alcohol content is part of a broader mixture, it may fall under 3824 (Other chemical products and preparations).

⚠️ Critical Note:
- "Low Carbon" implies saturation and mono-hydroxyl properties (Chapter 29 logic).
- "Mixture" often triggers the "Others" or "Other chemical products" bucket (Chapter 38 logic).
- The choice between Chapter 29 and 38 significantly impacts the Base Tariff Rate.


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

Based on the provided data, here are the four potential HS Codes, grouped by their logical classification path:

πŸ…°οΈ Path A: Classified as Saturated Alcohols (Chapter 29)

These codes apply if the product is recognized as a mixture of saturated alcohols.

HS Code Summary of Logic Total Tax Rate
2905.19.90.10 "Low carbon alcohol" fits the category of chain alcohols, matching the chemical properties of saturated monohydric alcohols. No material or form conflict. 38.7%
2905.19.90.90 The term "Alcohol" fits the material definition of saturated monohydric alcohol; "Low carbon" and "Mixture" characteristics fit the "Other" catch-all logic for this sub-category. 38.7%

πŸ…±οΈ Path B: Classified as Other Chemical Preparations (Chapter 38)

These codes apply if the product is deemed a mixture/preparation not elsewhere specified, often used as solvents or intermediates.

HS Code Summary of Logic Total Tax Rate
3824.99.93.30 "Low carbon alcohol" fits the material characteristic of "non-cyclic, mono-hydroxy, unsubstituted alcohols". It falls under the "Other" catch-all category with no material conflict. 40.0%
3824.99.93.10 "Low carbon alcohol" fits the material characteristic of "C11 or lower alcohols", and belongs to the "Mixture" form requirement. No material conflict. 40.0%

πŸ” 重点提醒 (Key Reminder):
- Chapter 29 Codes (2905...) generally have a lower Base Tariff (3.7%).
- Chapter 38 Codes (3824...) have a higher Base Tariff (5.0%).
- However, both paths incur significant additional tariffs due to trade restrictions (see Section III).


πŸ’° III. 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)

βœ… Applicable Country: United States (US)
βœ… Country of Origin: China (CN)
βœ… Effective Date: November 10, 2025 (and subsequent imports)

🎯 1. Chapter 29 Classification (Codes: 2905.19.90.10 & 2905.19.90.90)

Item Details
Base Tariff 3.7%
Section 301 Surcharge +25.0%
122 Clause Tariff +10.0%
Total Effective Rate 38.7%
Calculation CIF Value Γ— 38.7%
De Minimis Exemption ❌ Not Applicable (High-risk category for de minimis waiver in US-China trade context).

πŸ“Œ Explanation:
- The 3.7% is the standard MFN base rate for other saturated alcohols.
- The 25% is the standard Section 301 tariff on Chinese chemical goods.
- The 10% is an additional punitive tariff (often referred to as "122 Clause" or similar administrative surcharges in specific trade periods).
- Total: 38.7%.

🎯 2. Chapter 38 Classification (Codes: 3824.99.93.10 & 3824.99.93.30)

Item Details
Base Tariff 5.0%
Section 301 Surcharge +25.0%
122 Clause Tariff +10.0%
Total Effective Rate 40.0%
Calculation CIF Value Γ— 40.0%
De Minimis Exemption ❌ Not Applicable

πŸ“Œ Explanation:
- The 5.0% base rate is higher for "Other chemical products" compared to specific alcohols.
- The 25% and 10% surcharges remain identical.
- Total: 40.0%. This is the highest effective rate among the four options.


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

βœ… 1. Document Checklist (Mandatory)

Document Required Note
βœ… Product Specification Sheet βœ”οΈ Must list carbon chain length (e.g., C1-C11), concentration, and composition ratio.
βœ… Chemical Composition Analysis βœ”οΈ Prove whether it is a "Mixture of Alcohols" (Ch 29) or a "Chemical Preparation" (Ch 38).
βœ… Safety Data Sheet (SDS) βœ”οΈ Classify under GHS. Note flammability and hazard class (e.g., Class 3 Flammable Liquid).
βœ… Commercial Invoice βœ”οΈ Clearly state "Low Carbon Alcohol Mixture" and specify the HS Code chosen.
βœ… Packing List βœ”οΈ Indicate net/gross weight. Ensure packaging is compliant with IMDG/ADR if shipped by sea/air.

βœ… 2. Declaration Strategy (Key Mnemonic)

πŸ”₯ β€œBase Rate 3.7 vs 5.0, Choose 2905 if Pure, Choose 3824 if Mix, Total Tax 38.7% or 40%.”

Scenario Recommended HS Code Risk Level
Clear Blend of Specific Alcohols (e.g., Methanol/Ethanol mix) 2905.19.90.10 🟒 Low Risk (Logical fit)
Complex Industrial Mixture with unspecified components 3824.99.93.30 🟑 Medium Risk (May require Ruling)
C11 or Lower Alcohol Mix (Explicitly stated) 3824.99.93.10 🟑 Medium Risk
Generic "Other" Alcohol Mix 2905.19.90.90 🟒 Low Risk

⚠️ Critical Tip:
- Avoid declaring as "Solvent" without chemical details. If it is primarily alcohol, Chapter 29 is often preferred for lower base rates, but Chapter 38 is safer if the composition is vague or non-standard. - Do NOT split the shipment into "Alcohol" and "Other Chemicals" to avoid the 25% tariff. The 122 Clause and Section 301 apply to the entire entry if classified correctly.

βœ… 3. Special Handling Notes

Situation Handling Advice
High Concentration (>90%) Strongly lean towards Chapter 29. It is clearly a chemical substance.
Low Concentration / Formulated Mix Consider Chapter 38. It is a preparation for industrial use.
Dangerous Goods (DG) Alcohol is Class 3 Flammable. Ensure UN Number (e.g., UN1230 for Ethanol, UN1229 for Methanol) is declared. DG fees will apply regardless of HS Code.
Pre-Ruling Request Given the close tax difference (38.7% vs 40%) and the complexity of "Low Carbon," filing an Advance Ruling with CBP is highly recommended to lock in the 2905 classification if applicable.

🌍 V. Global Market Comparison (2026 Context)

Country/Region Recommended HS Code Est. Tariff (China Origin) Certification Note
πŸ‡ΊπŸ‡Έ USA 2905.19.90.10 / 3824.99.93.x 38.7% - 40.0% No specific certification, but DG compliance required. Highest tariff burden.
πŸ‡ͺπŸ‡Ί EU 2905.19.90 ~5-6% REACH Registration mandatory. No Section 301 surcharge.
πŸ‡¨πŸ‡³ China 2905.19.90 ~3.7-13% (Depends on exact code) No extra surcharge. Export tax rebate may apply.

πŸ“Œ Conclusion:
- The US market imposes a punitive 38.7%-40% tariff on Low Carbon Alcohol Mixtures from China.
- Supply chain diversification or Pre-Ruling for Chapter 29 is critical to minimize costs.


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

❌ Error 1: Declaring as "Solvent" without HS Code
πŸ‘‰ Consequence: Customs assigns default rate (often higher) or demands detailed chemical analysis β†’ Delays.

❌ Error 2: Choosing 3824 when 2905 is applicable
πŸ‘‰ Consequence: Paying 40.0% instead of 38.7%. While the difference seems small, on large volumes, it amounts to significant loss.

❌ Error 3: Ignoring the "Mixture" aspect
πŸ‘‰ Consequence: If the product is a mixture, Chapter 29 may reject it if it doesn't fit a specific "Mixture of Alcohols" subheading. However, 2905.19.90.10 explicitly accepts "Mixture" logic in the provided data.

βœ… Correct Approach:

"Low Carbon Alcohol Mixture (Saturated Monohydric Alcohols, C1-C11 Chain, Chemical Grade, UN1229/UN1230)"
HS Code: 2905.19.90.10 (Preferred for lower base rate)


🎯 VII. Conclusion: Precision Classification, Cost Control

🎯 Key Takeaway:

πŸ”Ή "Alcohol Mixture" in US-China Trade = High Tax (38.7%-40%).
πŸ”Ή "Low Carbon" + "Saturated" = Chapter 29 (2905.19.90.10) is likely the best fit.
πŸ”Ή "38.7% vs 40.0%" = Save the difference by choosing Chapter 29 if chemically defensible.


πŸ“Œ Pro Tip:

If your alcohol mixture contains other non-alcohol additives >5-10%, consider 3824.99.93.30. If it is >90% pure alcohol mixture, stick to 2905.19.90.10.


πŸ“£ Immediate Action:

πŸ“ž Apply for a CBP Advance Ruling before shipment.
πŸ“„ Ensure SDS accurately reflects carbon chain length and saturation.
πŸš€ Calculate landed cost with 38.7% tax included in your pricing model.


✨ Professional clearance starts with precise classification!
πŸ’Ό Every percentage point matters in high-tariff chemical trade.

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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.