Pencil Lead (4006100000)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 9609202000 | 17.5% | CN | US | Official Doc |
| 9609204000 | 17.5% | CN | US | Official Doc |
| 9609204000 | 17.5% | CN | US | Official Doc |
| 9609202000 | 17.5% | CN | US | Official Doc |
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AI Analysis
βοΈ Pencil Lead: Rubber vs. Graphite (4006.10.00.00 & 9609.20.xx)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π 1. Product Definition & Classification: Is Your "Pencil Lead" Actually Rubber?
In international trade, the term "Pencil Lead" is ambiguous. It usually refers to graphite/clay cores (Heading 9609), but if the product is made from vulcanized rubber (e.g., eraser leads, specialized rubber cores), it falls under Heading 4006.
The Critical Distinction:
Graphite/Clay Leads: Standard writing/drawing leads. β HS Code 9609.20.xx
Vulcanized Rubber Leads: Leads made from hard rubber or vulcanized rubber. β HS Code 4006.10.00.00
β οΈ Key Identification Point:
- If the material is graphite, clay, or mixed non-rubber compounds β Category 9609
- If the material is explicitly vulcanized rubber (even if used as a "lead") β Category 4006
π¦ 2. HS Code Classification Details (2026 Latest Tariff Authority)
Based on the provided data, here are the exact HS Codes and their tax implications. Note that 4006.10.00.00 appears twice in the source data, representing the same classification for rubber pencil leads.
| HS Code | Product Description | Material Composition | Max Cross-Section |
|---|---|---|---|
4006.10.00.00 |
Pencil leads made of vulcanized rubber | Vulcanized Rubber (Hard Rubber) | N/A (Specific to Heading 4006) |
9609.20.20.00 |
Graphite/Clay Pencil Leads (β€ 1.5mm) | Graphite, Clay, or Similar | β€ 1.5 mm |
9609.20.40.00 |
Graphite/Clay Pencil Leads (> 1.5mm) | Graphite, Clay, or Similar | > 1.5 mm |
π Important Note:
- The source data lists4006.10.00.00twice. This indicates a robust classification for rubber-based pencil leads.
- For standard graphite leads, the classification depends strictly on the maximum cross-sectional dimension:
- β€ 1.5 mm:9609.20.20.00
- > 1.5 mm:9609.20.40.00
π° 3. 2026 Latest Tariff Rate Breakdown (Including Additional Taxes)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: Current rates as per provided data
π― 1. 4006.10.00.00 ββ Pencil Lead (Vulcanized Rubber)
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% |
| Additional Tax (Section 301/IEEPA) | 0.0% |
| Total Tax Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0% = $0.00 |
| De Minimis Eligibility | β Yes (If value < $800, though rate is 0% anyway) |
| Legal Basis Path | USITC:4006.10.00.00 |
π Explanation:
- Zero Duty Advantage: Unlike graphite pencils, rubber-based pencil leads under Heading 4006 currently have no additional tariffs in the provided data.
- This makes4006.10.00.00a highly tariff-efficient classification for rubber-core products.
- Warning: Ensure the product is genuinely vulcanized rubber. Misclassifying graphite leads here will lead to penalties.
π― 2. 9609.20.20.00 ββ Pencil Lead (Graphite/Clay, β€ 1.5mm)
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% |
| Additional Tax (Section 301/IEEPA) | 7.5% |
| Total Tax Rate | 7.5% |
| Tax Calculation | CIF Value Γ 7.5% |
| De Minimis Eligibility | β No (Assumed subject to additional tax rules for China origin) |
| Legal Basis Path | USITC:9609.20.20.00 |
π Explanation:
- Standard graphite leads β€ 1.5 mm are subject to a 7.5% additional tax (likely Section 301).
- Base rate is 0%, but the total effective rate is 7.5%.
π― 3. 9609.20.40.00 ββ Pencil Lead (Graphite/Clay, > 1.5mm)
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% |
| Additional Tax (Section 301/IEEPA) | 7.5% |
| Total Tax Rate | 7.5% |
| Tax Calculation | CIF Value Γ 7.5% |
| De Minimis Eligibility | β No |
| Legal Basis Path | USITC:9609.20.40.00 |
π Explanation:
- Graphite leads > 1.5 mm are taxed identically to smaller leads: 7.5% total.
- Size does not affect the tax rate for graphite leads, only the HS Code sub-heading.
π οΈ 4. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Required Documentation Checklist (All Required)
| Document | Mandatory? | Explanation |
|---|---|---|
| β Product Composition Sheet | βοΈ | Must explicitly state material: "Vulcanized Rubber" vs. "Graphite/Clay" |
| β Material Safety Data Sheet (MSDS) | βοΈ | Helps customs verify rubber vs. graphite composition |
| β Commercial Invoice | βοΈ | Clearly describe item as "Pencil Lead (Rubber)" or "Graphite Pencil Lead" |
| β Cross-Sectional Measurement Proof | βοΈ | For graphite leads, provide photos/dimensions to prove β€1.5mm or >1.5mm |
| β Certificate of Origin (CO) | βοΈ | Confirm origin as China to apply correct additional tax |
β 2. Declaration Strategy (Key Mnemonics)
π₯ "Rubber is Free, Graphite is 7.5%, Size Matters for Graphite!"
| Scenario | Correct HS Code | Tax Rate | Error Risk |
|---|---|---|---|
| Rubber Pencil Lead | 4006.10.00.00 |
0.0% | β High (If misdeclared as graphite β 7.5%) |
| Graphite Lead β€ 1.5mm | 9609.20.20.00 |
7.5% | β Low |
| Graphite Lead > 1.5mm | 9609.20.40.00 |
7.5% | β Low |
| Mixed Box (Rubber + Graphite) | Split Declaration | 0% / 7.5% | β High (Must separate items) |
π Critical Reminder:
- Do not declare rubber pencil leads under9609.20.xx. Customs will reclassify and charge 7.5%.
- Do not declare graphite leads under4006.10.00.00. This is a false declaration and may result in penalties.
β 3. Special Handling Cases
| Situation | Handling Advice |
|---|---|
| OEM Custom Rubber Leads | Provide material specs showing vulcanization process. |
| Graphite Leads with Rubber Coating | If the core is graphite, classify under 9609.20.xx. The rubber coating is incidental. |
| Sample Shipments (< $800) | If rubber leads (4006.10.00.00), de minimis applies and tax is 0%. If graphite, de minimis may not apply due to additional tax rules (check latest CBP guidance). |
| Bulk Industrial Rubber Leads | Ensure HS Code 4006.10.00.00 is supported by MSDS and material certificates. |
π 5. Global Market Comparison (2026 Update)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ USA | 4006.10.00.00 (Rubber) |
0.0% | Best option for rubber leads |
| πΊπΈ USA | 9609.20.xx (Graphite) |
7.5% | Additional tax applies |
| π¨π³ China | 4006.10.00.00 |
~5-10% | Import tax applies |
| π¨π³ China | 9609.20.xx |
~10-15% | Standard graphite tariff |
| πͺπΊ EU | Varies | 0-6.5% | No Section 301 equivalent |
| π¬π§ UK | Varies | 0-6.5% | Post-Brexit tariffs apply |
π Conclusion:
- USA Market: Rubber pencil leads (4006.10.00.00) are tariff-free. Graphite leads face a 7.5% surcharge.
- Strategy: If your product allows, consider if a rubber-based lead is functionally acceptable to avoid tariffs.
π 6. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Calling all "pencil leads" "Graphite" even if they are rubber.
π Consequence: Incorrect HS Code β 7.5% tax owed + potential fines.
β Mistake 2: Ignoring the 1.5mm threshold for graphite leads.
π Consequence: Wrong sub-heading (20 vs 40). While tax is the same, it causes customs inspection delays.
β Mistake 3: Assuming "Pencil Lead" always means 9609.
π Consequence: Missing the 0% tariff opportunity for rubber leads under 4006.
β Mistake 4: No MSDS or Material Certificate.
π Consequence: Customs cannot verify rubber content β Detention & Testing Fees.
β Correct Practice:
"Pencil Lead, Vulcanized Rubber, Custom Diameter, Model RL-100, MSDS Attached"
π― 7. Conclusion: Precision Classification Saves Money!
π― Remember the Mnemonic:
πΉ "Rubber Leads = 0% Tax (4006)"
πΉ "Graphite Leads = 7.5% Tax (9609)"
πΉ "Size Matters for Graphite, Not for Tax Rate!"
π Pro Tip:
If you are importing graphite leads, consider if any part of the supply chain can shift to rubber-based alternatives to achieve 0% duty in the US market.
For graphite, ensure accurate cross-sectional measurement documentation to avoid classification disputes.
π£ Immediate Action:
π Confirm material composition with supplier.
π Obtain MSDS and dimensional reports.
π Declare accurately under4006.10.00.00or9609.20.xxas appropriate.
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Save 7.5% on every unit by getting the HS Code Right!
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.