Mullein Leaf Drops 60ml
CN β USAI Analysis
πΏ Mullein Leaf Drops (60ml) β Herbal Liquid Extract
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Bio-Pharma Strategy
π 1. Product Definition and Classification: What exactly is "Mullein Leaf Drops"?
Mullein Leaf Drops are a liquid herbal extract derived from the leaves of the Verbascum thapsus plant. In international trade, these products are typically classified based on their processing level and intended use (dietary supplement vs. medicinal drug).
Key Distinction: * Herbal Extract (Unprocessed/Simple Extraction): If the product is prepared by simple extraction (water, alcohol, glycerin) without adding synthetic active ingredients, it usually falls under Chapter 13 (Extracts) or Chapter 21 (Miscellaneous Food Preparations/Supplements). * Medicinal Product: If the drops contain standardized active compounds with declared therapeutic claims for treating specific diseases, they may be classified under Chapter 30 (Pharmaceutical Products).
β οΈ Critical Classification Point:
- If marketed as a Dietary Supplement (food category) β Look to HS 2106.90 or HS 1302.19.
- If marketed as a Registered Drug (pharmaceutical category) β Look to HS 3004.90.
- Most over-the-counter "Mullein Leaf Drops" are classified as dietary supplements/herbal extracts.
π¦ 2. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Application Scenario | Processing Level |
|---|---|---|---|
1302.19.30 |
Vegetable saps and extracts; alkaloids & glycosides (Other) | Standard herbal extracts, tinctures, tincture-like drops | β Extracted |
2106.90.92 |
Food preparations not elsewhere specified: Herbal extracts (for food use) | Dietary supplements, nutritional drops | β Food Grade |
3004.90.99 |
Medicaments consisting of mixed or unmixed products | Registered pharmaceutical drops with therapeutic claims | β Pharmaceutical |
2106.90.94 |
Other food preparations (Supplements) | Blended herbal drops with other non-medical ingredients | β Food Grade |
π Important Reminder:
- Most commercial Mullein Leaf Drops sold in health stores are classified under2106.90(Food Supplements) or1302.19(Extracts).
- If the product makes specific medical claims (e.g., "treats bronchitis"), customs may reclassify it as3004.90, which has different regulatory requirements.
- Base Tariff: Generally low (0β10%) for Chapter 13 and 21, but Chapter 30 may vary.
π° 3. 2026 Latest Tariff Rate Details (Including Surtax & Policy Surcharges)
β Applicable Country: USA (US)
β Country of Origin: China (CN)
β Effective Date: From November 10, 2025 (including subsequent imports)
π― 1. 1302.19.30 / 2106.90.92 β Herbal Extracts & Food Supplements
| Item | Content |
|---|---|
| Base Tariff | 0% β 5% (ad valorem) |
| USITC Surtax | +25% (USITC Footnote 9903.88.01 for certain extracts) |
| IEEPA Surtax | +10% (For China/HK origin, from Nov 10, 2025) |
| Total Tariff | ~35% β 40% |
| Tax Calculation | CIF Value Γ 35β40% |
| De Minimis Exemption | β Not Eligible (deny_de_minimis for surtaxed items) |
| Legal Authority Path | IEEPA:9903.01.25 β IEEPA:9903.01.24 β USITC:1302.19.30 β FOOTNOTE:9903.88.01 |
π Explanation:
- "USITC Surtax 25%" comes from the Section 301 tariffs on certain Chinese industrial and agricultural inputs; some herbal extracts fall under this.
- "IEEPA 10%" is the additional tariff imposed under the International Emergency Economic Powers Act on Chinese goods.
- Combined Total ~35β40%, which is significant for low-margin herbal products.
π― 2. 3004.90.99 β Pharmaceutical Products (If Classified as Drug)
| Item | Content |
|---|---|
| Base Tariff | 0% β 5% |
| USITC Surtax | +25% (If listed in surtax schedules) |
| IEEPA Surtax | +10% |
| Total Tariff | ~35% β 40% |
| De Minimis Exemption | β Not Eligible |
| Legal Authority Path | IEEPA:9903.01.25 β USITC:3004.90.99 |
π Note:
- If the product is considered a drug, it must comply with FDA regulations (New Drug Application or NDA exemptions).
- Customs may hold shipments if the product lacks proper FDA registration or is deemed an unapproved new drug.
π οΈ 4. Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (None Missing)
| Document | Must Provide | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Includes ingredients, concentration, extraction method (water/alcohol/glycerin) |
| β COA (Certificate of Analysis) | βοΈ | Proof of purity, heavy metal test, microbial limits |
| β Label Photo | βοΈ | Must show "Supplement Facts" or "Drug Facts" as applicable |
| β FDA Registration | βοΈ | Facility registration + Product listing (if dietary supplement) |
| β Commercial Invoice | βοΈ | Clearly state "Mullein Leaf Extract Drops" + "For Dietary Supplement Use" |
| β Certificate of Origin (CO) | βοΈ | If non-China origin, may apply for preferential rates |
| β Packing List | βοΈ | Net weight, gross weight, volume |
β 2. Declaration Tips (Key Mantra)
π₯ "Supplement Not Drug, Label Clear, Extracts Declared!"
| Situation | Correct Declaration | Wrong Practice |
|---|---|---|
| Herbal Drops (Dietary Supplement) | 2106.90.92 or 1302.19.30 |
Misdeclare as "Drug" β FDA Hold + Tariff Issues |
| Herbal Drops (Drug Claim) | 3004.90.99 |
Misdeclare as "Supplement" β Penalty + Seizure |
| Small Quantity (< $800) | Use De Minimis (if not surtaxed) | If surtaxed, must pay tariff even if < $800 |
| Blended Extracts | Declare all ingredients | Omitting active ingredients β Customs Rejection |
β 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| Alcohol-based Tinctures | Declare alcohol content >3% β May require DOT/PHMSA compliance if flammable |
| Glycerin-based Drops | Non-flammable, easier clearance |
| FDA Registered Facility | Ensure FDA Establishment Registration is valid and renewed annually |
| Structure/Function Claims | Allowed for supplements (e.g., "supports respiratory health"), but NOT disease treatment claims |
π 5. Global Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification Required | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 2106.90.92 / 1302.19.30 |
~35β40% (China Origin) | FDA Registration + GMP | High tariff due to surtax |
| π¨π³ China | 1302.19.30 |
5β10% | CFDA/NMPA Filing | No surtax |
| πͺπΊ EU | 1302.19 |
0β6% (if medicinal) | Novel Food / Traditional Herbal | Strict purity standards |
| π¦πΊ Australia | 1302.19 |
0β5% | TGA Listing | Therapeutic Goods Administration |
| π―π΅ Japan | 1302.19 |
0β10% | FIPF Notification | Food Safety Act compliance |
π Conclusion:
- USA has the highest effective tariff for Chinese-origin herbal supplements due to Section 301 and IEEPA surtaxes.
- EU and Japan have stricter safety/purity requirements but lower tariffs.
- China offers lower tariffs but requires NMPA compliance for import.
π 6. Common Mistakes & Pitfall Guide (Lessons from Tears)
β Mistake 1: Declaring "Mullein Drops" as "Food" without FDA Supplement Registration
π Consequence: FDA holds shipment β Detention + Return!
β Mistake 2: Making Disease Treatment Claims on Label (e.g., "Cures Bronchitis")
π Consequence: Reclassified as Unapproved Drug β Seizure + Fine!
β Mistake 3: Using De Minimis for Surtaxed Items
π Consequence: CBP rejects de minimis β Back taxes + Penalties!
β Mistake 4: Incomplete Ingredient Declaration
π Consequence: Customs requires additional testing β Delay + Storage Fees!
β Correct Approach:
"Dietary Supplement: Mullein Leaf Extract Drops in Glycerin Base. Supports Respiratory Health. FDA Registered Facility. No Drug Claims."
π― 7. Conclusion: Professional Declaration, Save Time & Money!
π― Remember the Mantra:
πΉ "Supplement Not Drug, Label Clear, Extracts Declared!"
πΉ "HS Code Determines Tariff, Claim Determines Compliance!"
π Pro Tip:
If your Mullein Drops are originating from Vietnam, India, or Thailand, you may qualify for IEEPA exemptions or lower Section 301 rates.
Recommendation: Apply for an Advance Ruling with CBP to confirm HS Code and tariff applicability before shipment.
π£ Immediate Action:
π Contact a Professional Customs Broker + Provide FDA Registration Number + Apply for HS Code Advance Ruling
π Ensure your Mullein Leaf Drops pass customs smoothly, comply with FDA, and maximize profit margins!
β¨ Professional Clearance, Starting with Precise Classification!
πΌ Every Cent of Cost Deserves Precise Calculation!
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.