Refined Wool Free Leather for Car Interior
CN โ US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 5111191000 | 42.0% | CN | US | Official Doc |
| 5111909000 | 60.0% | CN | US | Official Doc |
| 5112116030 | 60.0% | CN | US | Official Doc |
| 5112199510 | 60.0% | CN | US | Official Doc |
| 5407940520 | 12.0% | CN | US | Official Doc |
Product Images
AI Analysis
๐งถ Refined Wool Free Leather for Car Interior
(Note: Despite the name "Leather," the source data classifies this as Animal Hair/Fine Animal Wool)
๐ HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
๐ I. Product Definition & Classification: Is it "Leather" or "Wool"?
Refined Wool Free Leather is a marketing term often used in automotive interiors. However, in international trade and customs classification, the physical material determines the HS Code, not the marketing name.
Key Distinction:
"Leather" (Hide/Skin): If made from animal skin (cow, sheep hide), it falls under Chapter 41.
* "Wool/Hair": If made from fine animal hair (wool, cashmere, alpaca, etc.), it falls under Chapter 51*.
โ ๏ธ Critical Insight:
According to the provided data, this product is classified as Chapter 51 (Wool, Fine or Coarse Animal Hair). The term "Free Leather" likely implies a leather-like texture or finish, but the material composition is Fine Animal Hair (Wool). Therefore, we must look at Woven Fabrics of Animal Hair.
๐ฆ II. HS Code Classification Details (Based on Provided Data)
| HS Code | Product Description | Match Status | Material Form | Total Tax Rate |
|---|---|---|---|---|
5111.19.10.00 |
Fine animal hair automotive interior fabric, material is fine animal hair, form is woven, used for decoration. | โ ๏ธ Partial Match | Woven | 42.0% |
5111.90.90.00 |
Fine animal hair automotive interior fabric, material is fine animal hair, form is woven, Perfect Match. | โ Best Match | Woven | 60.0% |
5112.11.60.30 |
Fine animal hair automotive interior fabric, material is fine animal hair, form is fabric, Fits Classification Description. | โ Good Match | Fabric (Woven) | 60.0% |
5112.19.95.10 |
Fine animal hair automotive interior fabric, material is fine animal hair, form is fabric, Matches Classification. | โ Good Match | Fabric (Woven) | 60.0% |
5407.94.05.20 |
Fine animal hair automotive interior fabric, material is fine animal hair, form is woven, Fits Bottom-Up Inference. | ๐ก Fallback | Woven | 12.0% |
๐ Analysis:
Primary Classification: The product is most accurately described as a Woven Fabric of Fine Animal Hair (Chapters 5111 or 5112).
Tax Disparity: There is a massive tax difference between the wool-specific codes (42%-60%) and the fallback synthetic/other code (5407.94.05.20at 12%).
Risk: Customs may challenge a lower tax rate if the material is confirmed as "Fine Animal Hair." However, if the product is a blended fabric* where wool is not the dominant fiber, the fallback code might apply.
๐ฐ III. 2026 Latest Tariff Rate Breakdown (Including Surcharge & Policy Surcharges)
โ Applicable Country: United States (US)
โ Origin: China (CN)
โ Effective Date: From November 10, 2025 (including subsequent imports)
๐ฏ 1. Primary Wool Codes (5111.19.10.00, 5111.90.90.00, 5112.11.60.30, 5112.19.95.10)
| Item | Detail |
|---|---|
| Base Tariff | 7.0% (for 5111.19.10.00) or 25.0% (for 5111.90.90.00 etc.) |
| Section 301 Surcharge | +25.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 42.0% (for 5111.19.10.00) or 60.0% (for others) |
| Tax Calculation | CIF Value ร Total Rate |
| De Minimis Exemption | โ Not Eligible |
| Legal Basis Path | Base Tariff + Section 301 (USITC) + Section 122 (IEEPA) |
๐ Explanation:
Section 301 (25%): Standard US tariff on Chinese goods in this category.
Section 122 (10%): Specific surcharge for certain textile/apparel goods imported from China.
High Barrier: A 60% total tariff* is extremely high. This significantly impacts the landed cost.
๐ฏ 2. Fallback Code (5407.94.05.20)
| Item | Detail |
|---|---|
| Base Tariff | 0.0% |
| USITC Surcharge | +2.0% |
| Section 122 Tariff | +10.0% |
| Total Tax Rate | 12.0% |
| Tax Calculation | CIF Value ร 12% |
| De Minimis Exemption | โ Not Eligible |
| Legal Basis Path | Base Tariff (0%) + Surcharge (2%) + Section 122 (10%) |
๐ Caution:
This code is labeled as a "Bottom-Up Inference" (ๅ ๅบ็ฑป็ฎๆจๆญ).
Using this code requires proof that the product does NOT fit the specific description of "Fine Animal Hair Woven Fabric" in Chapters 5111/5112.
If Customs verifies the material is >50% fine animal hair, they will reject* this classification and demand the 60% rate.
๐ ๏ธ IV. Customs Clearance Practical Advice (Avoid Pitfalls)
โ 1. Documentation Checklist (Non-Negotiable)
| Document | Required | Description |
|---|---|---|
| โ Material Composition Certificate | โ๏ธ | Must specify % of wool, polyester, nylon, etc. |
| โ Lab Test Report | โ๏ธ | Microscopic fiber analysis to prove "Fine Animal Hair" content. |
| โ Product Photos (Close-up) | โ๏ธ | Show texture, weave, and label. |
| โ Commercial Invoice | โ๏ธ | List as "Automotive Interior Fabric" not just "Leather." |
| โ Packing List | โ๏ธ | Weight and dimensions. |
| โ Origin Certificate | โ๏ธ | To prove China origin. |
โ 2. Declaration Strategy
๐ฅ Key Motto:
"Material Dictates Code, Marketing Name Deceives!"
| Scenario | Correct Declaration | Risk |
|---|---|---|
| 100% Fine Wool | 5111.90.90.00 or 5112.11.60.30 |
High Tax (60%) |
| Wool Blend (<50% Wool) | 5407.94.05.20 (with proof) |
Low Tax (12%) but Audit Risk |
| Synthetic "Leather" (PU) | Chapter 59 or 39 | Not in provided data |
| Real Animal Hide Leather | Chapter 41 | Not in provided data |
โ 3. Special Handling
| Situation | Recommendation |
|---|---|
| Pre-Clearance Ruling | HIGHLY RECOMMENDED. Apply for an Advance Ruling from CBP to confirm the HS Code before shipment. |
| Material Blending | If the wool content is low, ensure the invoice and test report clearly state the lower fiber percentage. |
| "Free Leather" Misnomer | Do NOT declare as "Leather" (Chapter 41). This will cause a mismatch with physical goods and lead to seizure or heavy fines. |
| Cost Calculation | Include the 60% tax in your pricing model if using wool-specific codes. Only use the 12% rate if you have legal backing for the fallback code. |
๐ V. Global Market Comparison (2026)
| Country/Region | Recommended HS Code | Est. Tariff | Note |
|---|---|---|---|
| ๐บ๐ธ USA | 5111.90.90.00 |
60.0% | High due to Section 301 + 122 |
| ๐บ๐ธ USA | 5407.94.05.20 |
12.0% | Only if material composition supports it |
| ๐ช๐บ EU | 5111.19 or 5112.11 |
0% - 12% | No Section 301, but verify "Made in China" duties |
| ๐จ๐ณ China | 5111.19.10.00 |
~7% | Import duty into China |
๐ Conclusion:
The US market is the most challenging for this product due to the 60% total tariff.
To reduce costs, you must prove that the product does not meet the specific definition of "Fine Animal Hair Woven Fabric" in Chapters 5111/5112, allowing for the fallback code at 12%.
However, this carries a high audit risk. Pre-clearance ruling is essential.
๐ VI. Common Mistakes & Pitfalls
โ Mistake 1: Declaring as "Auto Leather" (Chapter 41)
๐ Consequence: Customs will reclassify to Chapter 51 based on material test โ 60% Tax + Penalty.
โ Mistake 2: Using 5407.94.05.20 without Lab Report
๐ Consequence: CBP rejects the claim, demands 60% tax + interest.
โ Mistake 3: Ignoring Section 122 Tariff
๐ Consequence: Under-declaration โ Fine and seizure.
โ Correct Approach:
"Automotive Interior Fabric, Woven, Composition: 40% Fine Animal Hair, 60% Polyester, Model XYZ, Certified Lab Report Attached."
๐ฏ VII. Conclusion: Professional Classification Saves Millions!
๐ฏ Remember the Rule:
๐น "Name is Marketing, Material is Law."
๐น "60% Tax on Wool, 12% on Fallback, Prove the Blend."
๐น "Get an Advance Ruling to Sleep Well."
๐ Pro Tip:
If your product is not made of fine animal hair, but is a synthetic fabric designed to look like leather, ensure your HS Code reflects the synthetic material (e.g., Chapter 54 or 59). If it is wool, budget for the 60% tariff or consult a customs broker for a Pre-Ruling.
๐ฃ Immediate Action:
๐ Contact a US Customs Broker โ Provide Material Test Report โ Request Pre-Ruling (Pre-Ruling Application)
๐ Ensure Compliance, Avoid Seizure, Optimize Costs!
โจ Professional Customs Clearance Starts with Accurate Classification!
๐ผ Your Profit Margin Depends on Your HS Code!
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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) โ Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) โ More specific grouping within the chapter
- Subheading (6 digits) โ Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) โ 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 โ The standard duty rate applied to WTO members
- General rate โ Applied to countries without trade agreements
- Trade remedy duties โ 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.