Methyl Chloroform Cleaner Low Residue
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3814005010 | 41.0% | CN | US | Official Doc |
| 2903196010 | 40.5% | CN | US | Official Doc |
| 3824995000 | 41.5% | CN | US | Official Doc |
| 3824995500 | 38.7% | CN | US | Official Doc |
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AI Analysis
π§ͺ Methyl Chloroform Cleaner (Low Residue) | 1,1,1-Trichloroethane (CAS 71-55-6)
π HS Code Reference & Clearance Guide | 2026 Latest Harmonized System Analysis | High-Risk Chemical Clearance Strategy
π I. Product Definition & Classification: Is It Really "Just Cleaner"?
Methyl Chloroform Cleaner (Low Residue), chemically known as 1,1,1-Trichloroethane (1,1,1-TCE), is a potent halogenated solvent widely used in industrial parts cleaning, degreasing, and dry cleaning. The "Low Residue" specification refers to the purity level and lack of stabilizers or additives that leave films after evaporation.
In international trade, it is strictly categorized as a Halogenated Hydrocarbon Solvent. Due to its ozone-depleting potential, its classification is heavily scrutinized and restricted under the Montreal Protocol.
β οΈ Key Distinction:
- Industrial Grade (Pure): Primary solvent for precision cleaning β Classified under 2903.29
- Formulated Cleaner (With Additives/Surfactants): If mixed with other chemicals to form a ready-to-use solution β May fall under 3824.99 or 3402 depending on composition.
- Aerosol Spray: If packaged as an aerosol, it requires additional safety classifications β 3824.99 or 3307.90 (if cosmetic/perfume related, unlikely for this item).
π¦ II. HS Code Classification Details (2026 Latest Tariff Schedule)
| HS Code | Product Description | Applicable Scenario | Contains Additives? |
|---|---|---|---|
2903.29.00 |
1,1,1-Trichloroethane (Methyl Chloroform) | Pure solvent, bulk liquid, industrial grade | β No (Pure chemical) |
3824.99.92 |
Other prepared binding agents; other chemical products | Ready-to-use cleaners with stabilizers, corrosion inhibitors | β Yes |
3824.99.99 |
Other chemical products (unspecified) | Mixtures where the specific chemical name is not declared or complex blends | β Yes (Complex mix) |
3402.90.00 |
Surface-active agents prepared | If the primary function is surfactant-based cleaning (rare for pure methyl chloroform) | β N/A |
9802.00.90 |
Goods returned or re-exported | If this is reclaimed/recycled solvent returning to the country | β N/A |
π Critical Note:
- Most "Methyl Chloroform Cleaner" imported as a bulk chemical is classified under2903.29.00.
- If the product is sold as a pre-mixed "parts cleaner" with added surfactants or fragrances, customs may reclassify it under3824.99.
- Always check the Safety Data Sheet (SDS). If Section 3 lists only 1,1,1-Trichloroethane >99%, use2903.29.00.
π° III. 2026 Latest Tariff Rate Breakdown (High-Risk Chemicals)
β Destination Country: United States (US)
β Origin Country: China (CN) or Other Non-FDI Countries
β Effective Date: 2026 Tariff Schedule
π― 1. 2903.29.00 ββ 1,1,1-Trichloroethane (Pure Solvent)
| Item | Content |
|---|---|
| Base MFN Rate | 3.2% (ad valorem) |
| Section 301 Duty (China Origin) | +25% (List 4B) |
| IEEPA Surcharge | +10% (Targeted Chemicals/Solvents, 2025-2026 Policy) |
| Environmental Protection Fee | Varies by state (e.g., California VOC fees) |
| Total Effective Duty | ~38.2% |
| Tax Calculation | CIF Value Γ 38.2% |
| De Minimis Eligibility | β Denied (Chemicals are excluded from Section 321 de minimis) |
| Legal Authority | HTSUS:2903.29.00 β USITC Footnote 5 β Section 301 List 4B β IEEPA Executive Order 14117 |
π Explanation:
- 1,1,1-Trichloroethane is a controlled substance under the Montreal Protocol.
- The Section 301 (25%) applies to many chemical products from China.
- The IEEPA 10% surcharge may apply to specific strategic chemicals depending on the latest 2026 directive.
- High Tax Impact: The cumulative burden exceeds 38%, significantly eroding margins.
π― 2. 3824.99.92 ββ Prepared Cleaners (With Additives)
| Item | Content |
|---|---|
| Base MFN Rate | 5.3% |
| Section 301 Duty | +25% (Many chemical preparations are on List 4A/4B) |
| IEEPA Surcharge | +10% (If deemed strategic) |
| Total Effective Duty | ~40.3% |
| De Minimis Eligibility | β Denied |
π Warning:
- Classifying as "Prepared Cleaner" often increases the base duty rate (5.3% vs 3.2%) while attracting the same surcharges.
- Only use3824if the product contains >10% non-solvent additives.
π οΈ IV. Customs Clearance Practical Advice (Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Required? | Notes |
|---|---|---|
| β Safety Data Sheet (SDS) | βοΈ Mandatory | Must comply with OSHA HazCom Standard. Section 14 (Transport Info) is critical. |
| β Bill of Lading / Air Waybill | βοΈ Mandatory | Must clearly state "1,1,1-Trichloroethane" or "Methyl Chloroform". |
| β Import License (EPA) | βοΈ CRITICAL | 1,1,1-TCE is a Class I ODS (Ozone Depleting Substance). EPA import license is required. |
| β Certificate of Origin | βοΈ Mandatory | To claim any potential FTZ benefits (rare for this chemical) or prove non-China origin. |
| β SDS for Packaging | βοΈ Recommended | If shipped in drums, ensure UN-rated packaging is certified. |
| β EPA Notification | βοΈ Mandatory | TSCA (Toxic Substances Control Act) notification required before import. |
β 2. Declaration Tips (Key Mnemonics)
π₯ "Chemical Name, CAS #, SDS, EPA License β Without These, Cargo Stops!"
| Scenario | Correct Declaration | Error to Avoid |
|---|---|---|
| Pure 1,1,1-TCE | 2903.29.00, "1,1,1-Trichloroethane, CAS 71-55-6" |
Using vague terms like "Cleaning Agent" β Seizure Risk |
| Mixed Cleaner | 3824.99.92, "Prepared Parts Cleaner, Contains 95% 1,1,1-TCE" |
Omitting additive info β Misclassification |
| Recycled Solvent | 9802.00.90, "Returned Chemical Goods" |
Failing to prove original export β Denial of Preference |
β 3. Special Handling & Regulatory Notes
| Issue | Handling Advice |
|---|---|
| EPA Import License | Apply for EPA Import License 30 days prior to shipment. Without it, goods will be rejected at US border. |
| VOC Regulations | Many US states (CA, NY, MA) have strict VOC limits. Ensure product complies with state-level regulations. |
| Packaging | Must be UN-certified packaging (e.g., UN 1A1, 1A2, 1H1). Poor packaging leads to re-packing fees or rejection. |
| Dangerous Goods (DG) | Classified as Class 3 Flammable Liquid (Flash point ~12Β°C). Air freight requires DG declaration and IATA compliance. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 2903.29.00 |
~38.2% (incl. duties) | EPA License, TSCA, OSHA SDS | Strictest on ODS chemicals. |
| π¨π³ China | 2903.29.00 |
0% (Import Duty) | MSDS, CIQ Inspection | Allowed for industrial use only. |
| πͺπΊ EU | 2903 29 90 |
6.5% | REACH Registration, CLP Labeling | REACH registration is mandatory for importers. |
| π―π΅ Japan | 2903.29.00 |
3.6% | Chemical Substances Control Law (CSCL) | Requires notification if volume >1 ton/year. |
| π¦πΊ Australia | 2903.29.00 |
5.0% | NICNAS/AGLC Registration | Strict handling and storage laws. |
π Conclusion:
- USA and EU are the most regulated markets for 1,1,1-Trichloroethane.
- EPA License (USA) and REACH (EU) are the biggest hurdles.
- Tariffs are high due to geopolitical tensions and environmental concerns.
π VI. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Declaring as "Cleaning Solution" without specifying chemical composition.
π Consequence: Customsζη (Suspects) undeclared hazardous chemicals β Inspection Delay & Fines.
β Mistake 2: Forgetting the EPA Import License for 1,1,1-TCE.
π Consequence: Cargo Rejected/Destroyed at US Port of Entry. No refund.
β Mistake 3: Using non-UN packaging for flammable liquids.
π Consequence: Refused by carrier (Airline/Shipping Line) β Re-packing costs or shipment cancellation.
β Mistake 4: Not disclosing "Low Residue" implies purity, but additives are hidden.
π Consequence: Misclassification β Back taxes & penalties for under-declared duty rates.
β Correct Practice:
"1,1,1-Trichloroethane (Methyl Chloroform), CAS 71-55-6, Industrial Grade, >99.5% Purity, For Parts Cleaning, UN 1A2 Drum, EPA License #XXX"
π― VII. Conclusion: Professional Clearance for High-Risk Chemicals
π― Remember the Golden Rules:
πΉ "EPA License First, SDS Always, Chemical Name Specific."
πΉ "1,1,1-TCE is ODS β Regulated, Taxed, and Scrutinized."
πΉ "Do Not Vague-Name β 'Cleaner' is not a HS Code."
π Pro Tip:
If your product is reclaimed/recycled 1,1,1-TCE, consider declaring under 9802.00.90 if it qualifies as "returned goods," which may reduce duty. However, you must prove original export and lack of value addition. Consult a customs broker for advance ruling.
π£ Immediate Action Required:
π Verify EPA License Status
π Prepare OSHA-Compliant SDS (16-Section)
π¦ Confirm UN-Certified Packaging
π Ensure Smooth Customs Clearance for Hazardous Chemicals!
β¨ Precision in Chemical Classification Saves Thousands!
πΌ Compliance is Not Optional β Itβs the Price of Entry.
Customer Reviews
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.