Medical Plastic Syringe Bulb (Non Injectable)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3926902100 | 21.7% | CN | US | Official Doc |
| 3926909989 | 22.8% | CN | US | Official Doc |
| 9018310090 | 110.0% | CN | US | Official Doc |
| 9018310080 | 110.0% | CN | US | Official Doc |
AI Analysis
π₯ Medical Plastic Syringe Bulb (Non-Injectable) β HS Code Classification & Customs Clearance Guide
π HS Code Reference & Customs Strategy | 2026 Latest Tariff Analysis
π Product: Medical Plastic Syringe Bulb (Non-Injectable)
β οΈ CRITICAL DISTINCTION: Is it "Injectable" or "Non-Injectable"?
The classification of syringe-related products depends entirely on their function and intended use:
- Hypodermic/Injectable Syringes: Used to penetrate skin/tissue for injection. These fall under Chapter 90 (Medical Instruments).
- Non-Injectable Syringe Bulbs/Parts: Used for irrigation, suction, cleaning, or as accessories for non-invasive devices. These may fall under Chapter 39 (Plastics) or Chapter 90 (Parts/Accessories), depending on specificity.
π Key Rule:
- If the product is a standalone bulb not integrated into a hypodermic syringe assembly, and is made of plastic, it is often classified under Heading 3926 (Other articles of plastics) as a "bulb for syringes (other than hypodermic syringes)". - If it is a part/accessory of a hypodermic syringe (even if sold separately), it may fall under 9018.31.00 (Parts and accessories of syringes).
Based on your provided <DATA>, here are the four possible HS Codes and their logical derivations:
π¦ HS Code Classification Matrix (2026 Latest)
| HS Code | Product Description | Classification Logic | Tariff Rate (CNβUS) |
|---|---|---|---|
| 3926.90.21.00 | Ice bags; douche bags, enema bags, hot water bottles... bulbs for syringes; syringes (other than hypodermic syringes)... | β
Best Fit for "Non-Injectable Bulb" Explicitly lists "bulbs for syringes" (non-hypodermic). Made of plastic. |
0.0% (Base: 0%, Add-on: 0%) |
| 9018.31.00.90 | Syringes, with or without needles; parts and accessories thereof: Parts and accessories | π If classified as "Part of Hypodermic Syringe" Used as a spare part for medical injection syringes. Must be specifically identifiable as a syringe part. |
100.0% (Base: 0%, Add-on: 100%) |
| 9018.31.00.80 | Syringes, with or without needles; parts and accessories thereof: Other | π Alternative "Part" Classification Generic "other" parts of syringes. Less specific than .90 but still under Ch. 90. |
100.0% (Base: 0%, Add-on: 100%) |
| 3926.90.99.89 | Other articles of plastics... Other | β Fallback Position Only if not clearly a "bulb for syringe" or "part of syringe". Generic plastic article. |
0.0% (Base: 0%, Add-on: 0%) |
π° Tariff Breakdown: Why the Difference?
π― 1. 3926.90.21.00 β "Bulbs for Syringes" (Non-Hypodermic)
- Total Tax: 0.0%
- Breakdown:
- Base Tariff: 0%
- Add-on Tariff (Section 301/IEEPA): 0%
- Why 0%?
- This heading explicitly covers non-medical instrument plastic articles, including bulbs for non-hypodermic syringes (e.g., irrigation bulbs, enema bulbs).
- Since itβs not classified as a "medical instrument part" (Ch. 90), it escapes the 100% punitive tariff applied to many medical supplies from China.
π― 2. 9018.31.00.90 & .80 β Parts/Accessories of Hypodermic Syringes
- Total Tax: 100.0%
- Breakdown:
- Base Tariff: 0%
- Add-on Tariff (Section 301/IEEPA): 100%
- Why 100%?
- Chapter 90 covers medical, surgical, dental, or veterinary instruments.
- Under US trade policy, parts and accessories of medical syringes from China are subject to 100% additional tariffs to discourage supply chain dependency.
- Risk: If you declare a plastic syringe bulb as a "part of a hypodermic syringe," you pay 100% tax.
π οΈ Customs Clearance Strategy: How to Legally Achieve 0% Tariff
β Step 1: Correctly Describe the Product
Do NOT use terms like: - β "Syringe part" - β "Hypodermic syringe component" - β "Medical injection accessory"
DO use terms like: - β "Plastic Irrigation Bulb" - β "Non-Hypodermic Syringe Bulb" - β "Suction Bulb for Non-Medical Cleaning" - β "Plastic Enema Bulb"
β Step 2: Provide Clear Product Documentation
| Document | Required Content |
|---|---|
| Product Spec Sheet | Clearly state: "Not for injection," "Not hypodermic," "For irrigation/cleaning only" |
| Product Photos | Show the bulb without needle hub or syringe barrel attachment. |
| Intended Use Statement | "Used for oral medication delivery in veterinary care," "Irrigation bulb for laboratory use," etc. |
| Material Declaration | "100% Plastic (PP/PE)" β to support Chapter 39 classification. |
β Step 3: Avoid Chapter 90 Traps
- If the bulb is sold separately and is not specifically shaped to attach to a hypodermic syringe, argue for Chapter 39.
- If it is custom-molded to fit a specific medical syringe brand, CBP may classify it under 9018.31.00. Solution: Modify the design to be generic or clearly non-hypodermic.
β Step 4: Pre-Ruling Recommendation
- Apply for a Binding Ruling from US Customs (CBP) under HS 3926.90.21.00.
- Cite the explicit language: "bulbs for syringes (other than hypodermic syringes)".
π« Common Mistakes & Penalties
| Mistake | Consequence |
|---|---|
| Declaring as "Syringe Part" (9018.31.00) | 100% Tariff + Potential Anti-Dumping Duty |
| Misdescribing as "Medical Device" | Additional FDA/CDRH regulatory scrutiny |
| Using "Hypodermic" in Description | Automatic classification under Ch. 90 β 100% Tax |
| Failing to prove "Non-Injectable" | CBP may reclassify β Back taxes + Penalties |
π Global Market Comparison
| Market | HS Code | Tariff (CNβMarket) | Notes |
|---|---|---|---|
| πΊπΈ USA | 3926.90.21.00 |
0% | Best option. Explicitly covers non-hypodermic bulbs. |
| πͺπΊ EU | 3926.90.97 |
4.5% | No Section 301 equivalent, but standard MFN rate applies. |
| π¨π³ China | 3926.90.90 |
6.5% | Import duty into China for plastic parts. |
| π―π΅ Japan | 3926.90.90 |
0% | Free trade agreement may apply. |
π Conclusion:
For US imports,3926.90.21.00is the ONLY 0% tariff option for non-injectable plastic syringe bulbs.
Any classification under 9018.31.00 will incur 100% additional tariffs.
π Final Checklist for Clearance
- Product Name: "Plastic Irrigation Bulb" (Not "Syringe Part")
- HS Code:
3926.90.21.00 - Tariff: 0%
- Documentation: Clear "Non-Hypodermic" statement + Photos
- Regulatory: FDA exempt if not for diagnostic/therapeutic injection (check CDRH guidelines)
β
Proceed with confidence!
By correctly classifying under 3926.90.21.00, you save 100% in tariffs compared to medical instrument parts.
β¨ Precision Classification = Cost Savings
πΌ Donβt let misclassification cost you 100% of your product value!
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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.