Manual Breast Pump
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 8509805095 | 14.2% | CN | US | Official Doc |
| 9018907560 | 35.0% | CN | US | Official Doc |
| 9018908000 | 10.0% | CN | US | Official Doc |
| 8509805045 | 14.2% | CN | US | Official Doc |
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πΆ Breast Pump (Manual & Electric) β The Ultimate Import Guide for 2026
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π One Product, Multiple Classifications: Why the "Breast Pump" Tariff Varies Wildly
A breast pump is a versatile device that bridges the gap between consumer electronics and medical devices. Because its classification depends on whether it is viewed as a "home appliance with an electric motor" or a "medical nursing instrument," the HS Code assignmentβand consequently the tariffβcan differ drastically.
Below is the breakdown based on the 2026 Data Provided, covering all four possible classifications for Breast Pumps (both manual and electric variants where applicable).
β οΈ Critical Distinction:
- Electric Breast Pumps: Must have an internal battery or plug-in motor. Eligible for 8509 (Home Appliances) or 9018 (Medical Instruments).
- Manual Breast Pumps: No motor. Typically classified under 9018 (Medical/Nursing Instruments) as they are primarily for nursing/care purposes.
- Misclassification Risk: Classifying a medical-grade electric pump as a simple "home appliance" may trigger audits if regulatory bodies (like the FDA) classify the product as a medical device.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description & Logic | Total Tax Rate | Tax Breakdown (Base + Surtax + Section 301/122) |
|---|---|---|---|
| 8509.80.50.95 | Home Appliance Logic: Electric breast pumps classified as "Other" home appliances with self-contained electric motors. | 14.2% | Base: 4.2% Surtax: 0.0% Section 122 (China): 10% |
| 8509.80.50.45 | Home Appliance Logic: Electric breast pumps with self-contained motors, similar to electric toothbrushes in functional attributes. | 14.2% | Base: 4.2% Surtax: 0.0% Section 122 (China): 10% |
| 9018.90.75.60 | Medical/Treatment Logic: Treated as medical/surgical/nursing auxiliary therapeutic equipment. | 35.0% | Base: 0.0% Surtax: 25.0% Section 122 (China): 10% |
| 9018.90.80.00 | Medical/Nursing Logic: Instruments for medical/surgical/dental/veterinary purposes, specifically "Other" medical/nursing apparatus. | 10.0% | Base: 0.0% Surtax: 0.0% Section 122 (China): 10% |
π Key Insight:
- Cheapest Option:9018.90.80.00at 10.0% (if classified strictly as general medical/nursing instruments without surtaxes).
- Most Expensive Option:9018.90.75.60at 35.0% (due to 25% surtax on therapeutic equipment).
- Home Appliance Route:8509codes are capped at 14.2%, but may face stricter regulatory scrutiny (FDA) if marketed as medical devices.
π° III. 2026 Latest Tariff Rate Explanation (Detailed Breakdown)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: 2025β2026 (Current Trade Environment)
π― 1. 8509.80.50.95 & 8509.80.50.45 ββ Home Appliances with Electric Motors
| Item | Content |
|---|---|
| Base Tariff | 4.2% (General Rate for Home Appliances) |
| USITC Surtax | 0.0% (No specific surtax for this subheading under current rules) |
| Section 122/301 Tax | +10% (Specific tariff for Chinese-origin goods under this classification) |
| Total Effective Rate | 14.2% |
| Calculation | CIF Value Γ 14.2% |
| De Minimis Eligibility | β No (High value items usually excluded; manual pumps may qualify if low value, but electric pumps likely do not) |
| Legal Basis | HTSUS Chapter 85 (Electrical Machinery) |
π Explanation:
- These codes treat the breast pump as a consumer good (like a blender or toothbrush).
- The 10% additional tariff is fixed for this category.
- Pros: Lower tax burden (14.2%) compared to some medical codes.
- Cons: May require FCC Certification (for electric motors) and FDA Registration (if marketed as a nursing device).
π― 2. 9018.90.75.60 ββ Medical/Treatment Equipment
| Item | Content |
|---|---|
| Base Tariff | 0.0% |
| USITC Surtax | +25.0% (High surtax for therapeutic/medical devices) |
| Section 122/301 Tax | +10.0% |
| Total Effective Rate | 35.0% |
| Calculation | CIF Value Γ 35.0% |
| De Minimis Eligibility | β No |
| Legal Basis | HTSUS Chapter 90 (Optical, Photographic, Medical Equipment) |
π Explanation:
- This code applies if the pump is considered therapeutic equipment (e.g., treating mastitis or enhancing milk production via medical mechanisms).
- The 25% surtax significantly increases costs.
- Risk: High scrutiny from FDA for therapeutic claims.
π― 3. 9018.90.80.00 ββ Other Medical/Surgical/Nursing Instruments
| Item | Content |
|---|---|
| Base Tariff | 0.0% |
| USITC Surtax | 0.0% (No surtax for this specific "Other" subheading) |
| Section 122/301 Tax | +10.0% |
| Total Effective Rate | 10.0% |
| Calculation | CIF Value Γ 10.0% |
| De Minimis Eligibility | β No (unless value < $800 for B2C, but B2B typically no) |
| Legal Basis | HTSUS Chapter 90 |
π Explanation:
- This is the most cost-effective medical classification.
- It covers "Other" instruments for nursing purposes without the therapeutic surtax.
- Best For: Manual breast pumps and basic electric pumps marketed as nursing aids rather than medical devices.
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
β 1. Document Checklist (Non-Negotiable)
| Document | Required | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state: Manual vs. Electric, Power Source, Material (BPA-Free) |
| β FDA Registration & Listing | βοΈ | Critical. If marketed as a nursing device, FDA clearance is mandatory. |
| β Certificate of Free Sale | βοΈ | From country of origin, confirming legal sale. |
| β Commercial Invoice | βοΈ | Must match HS Code and clearly describe the product (e.g., "Manual Breast Pump, Silicone, No Motor"). |
| β Labeling & Packaging Photos | βοΈ | Must show intended use, warnings, and ingredients/materials. |
| β FCC Certification (Electric Only) | βοΈ | For 8509 codes, FCC ID is required for electric motors. |
β 2. Classification Strategy (Key Tips)
π₯ βManual = 9018.80, Electric = 8509 OR 9018.75/80β
| Product Type | Recommended HS Code | Why? |
|---|---|---|
| Manual Breast Pump | 9018.90.80.00 |
No motor β Not a home appliance. Best as "Nursing Instrument" with lowest tax (10%). |
| Electric Breast Pump | 8509.80.50.95 |
If marketed as consumer electronics/home appliance. Tax: 14.2%. Requires FCC. |
| Therapeutic Electric Pump | 9018.90.75.60 |
Only if claimed to treat medical conditions (e.g., blocked ducts). Tax: 35%. High risk. |
| General Nursing Aid | 9018.90.80.00 |
If electric but marketed strictly as a "nursing aid" without therapeutic claims. Tax: 10%. |
π Warning:
- Do NOT classify an electric pump as9018.90.80.00if it has an FCC-regulated motor, unless you have strong legal justification.
- Manual pumps cannot go under8509because they lack an electric motor.
β 3. Special Handling Cases
| Scenario | Handling Advice |
|---|---|
| OEM Private Label | Provide brand authorization letters. Ensure FDA listing matches the importer. |
| Bundles (Pump + Accessories) | Declare as a single unit. Do not split into "pump" and "bottles" unless necessary. Bottles may have different rates. |
| Used/Refurbished Pumps | Strictly Prohibited for import into the US without specific FDA exemptions. Assume NEW only. |
| Low-Value Samples (<$800) | May qualify for De Minimis exemption (Section 321), but still need FDA compliance. |
π V. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification Required | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 9018.90.80.00 (Manual) 8509.80.50.95 (Electric) |
10% (Manual) 14.2% (Electric) |
FDA + FCC (Electric) | Strict on medical claims. |
| πͺπΊ EU | 9018.39 (Medical Devices) |
0% (if MDR compliant) | CE Mark + MDR | Manual pumps often under "personal care." |
| π¨π³ China | 9018.90 |
0β6% | NMPA | Lower tariffs for medical devices. |
| π¬π§ UK | 9018.90 |
0% (if post-Brexit rules apply) | UKCA Mark | Similar to EU but UK-specific. |
| π¦πΊ Australia | 9018.90 |
0β5% | TGA + SAA | Check TGA registration for electric pumps. |
π Conclusion:
- USA is the most complex due to the Section 122/301 tariffs and FDA overlap.
- Manual pumps consistently benefit from lower tariffs (10%) when classified as nursing instruments.
- Electric pumps face higher regulatory hurdles (FCC + FDA) but can be optimized to 14.2%.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Classifying an electric breast pump under 9018.90.75.60
π Consequence: 35% tariff due to 25% surtax.
π Fix: Use 9018.90.80.00 (10%) if not therapeutic, or 8509.80.50.95 (14.2%) as a home appliance.
β Mistake 2: Classifying a manual breast pump under 8509
π Consequence: Rejection/Seizure because there is no electric motor.
π Fix: Use 9018.90.80.00.
β Mistake 3: Ignoring FDA Registration for breast pumps
π Consequence: Detention at port by CBP pending FDA review.
π Fix: Ensure FDA Establishment Registration and Device Listing are complete before shipment.
β Mistake 4: Splitting bundled shipments (Pump + Bags + Valves)
π Consequence: Complex valuation, potential higher tax on accessories.
π Fix: Declare as a single unit "Breast Pump Kit" with the primary item's HS Code.
β Correct Declaration Example:
"Manual Breast Pump, Silicone & Polypropylene, No Electric Motor, For Nursing Assistance, Model XYZ, FDA Registered"
π― VII. Conclusion: Smart Classification, Lower Costs, Faster Clearance
π― Remember the Golden Rules:
πΉ "Manual = 9018.80 (10%), Electric = 8509 (14.2%) or 9018.80 (10%)"
πΉ "Avoid 9018.75 (35%) unless you claim therapeutic treatment"
πΉ "No FDA? No Entry. No Motor? Not 8509."
π Pro Tip:
- If you are importing manual pumps, always use 9018.90.80.00 for the lowest duty (10%).
- For electric pumps, compare 8509.80.50.95 (14.2%) vs. 9018.90.80.00 (10%). If you can justify 9018.80 without triggering therapeutic claims, save 4.2%.
- Always get an Advance Ruling from US CBP if you are unsure, to avoid post-entry audits and penalties.
π£ Immediate Action:
π Consult your customs broker with product photos and FDA certificates.
π Optimize your HS Code to save up to 25% in tariffs.
πΌ Professional clearance starts with precise classification!
β¨ Expert Clearance, Precise Classification, Maximized Profit!
πΌ Every dollar saved in duty is a dollar added to your margin!
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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.