Refrigerant Mixture (for Air Conditioners)
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 2903490000 | 13.7% | CN | US | Official Doc |
| 3827690000 | 38.7% | CN | US | Official Doc |
| 3824995500 | 38.7% | CN | US | Official Doc |
| 3827390000 | 38.7% | CN | US | Official Doc |
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π‘οΈ Refrigerant Mixture (for Air Conditioners)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
π Part 1: Product Definition & Classification: What is a Refrigerant Mixture?
Refrigerant mixtures are complex chemical blends used primarily in air conditioning and refrigeration systems to transfer heat. In international trade, they are NOT classified as simple "gases" or "liquids" but are treated as chemical mixtures or halogenated hydrocarbon derivatives.
The classification depends heavily on the specific chemical composition (e.g., presence of Fluorine, Chlorine, Hydrogen) and the state of the mixture. Misclassification here can lead to severe penalties due to the high "Section 301" (25%) and "Section 232/IEEPA" (10%) tariffs attached to many chemical imports from China to the US.
β οΈ Critical Distinction:
- Halogenated Hydrocarbon Derivatives (Saturated): Often fall under 2903.49 (Lower Base Duty).
- Other Hydrofluorocarbons (HFCs) or Halogenated Mixtures: Often fall under 3827 or 3824 (Higher Base Duty + High Add-ons).
- HCFCs/Chlorinated Mixtures: Fall under 3827.39 (High Add-ons).
π¦ Part 2: HS Code Classification Details (2026 Latest Tariff Authority)
Based on the provided data, here are the four most likely HS Codes for Refrigerant Mixtures, ranked by potential tax liability and chemical logic.
| HS Code | Product Description | Applicable Scenario | Chemical Basis |
|---|---|---|---|
2903.49.00.00 |
Halogenated hydrocarbon derivatives, saturated fluorinated acyclic derivatives | Pure or mixed saturated fluorinated non-cyclic hydrocarbon derivatives (e.g., certain R-134a blends if strictly defined as derivatives) | β Saturated Fluorinated Derivatives |
3827.69.00.00 |
Other hydrofluorocarbons (HFCs) | Mixtures containing halogenated derivatives of methane, ethane, or propane (Common R-4xx, R-5xx series blends) | β HFC-Based Blends |
3824.99.55.00 |
Other chemical products (ε εΊ/Residual) | Halogenated hydrocarbon mixtures that do not fit specific chemical headings (Catch-all category) | β Generic Halogenated Mixtures |
3827.39.00.00 |
Halogenated hydrocarbons (HCFCs/Chlorinated) | Mixtures containing hydrochlorofluorocarbons (HCFCs) or related derivatives | β Chlorinated/HCFC-Based |
π Key Reminder:
- R-410A, R-404A, R-407C typically fall under 3827.69.00.00 or 3824.99.55.00 because they are complex mixtures of HFCs, not pure chemical derivatives. - R-22 (HCFC) falls under 3827.39.00.00. - 2903.49.00.00 is rare for "mixtures" unless they are specifically defined as single-entity derivatives under Chapter 29, which is less common for commercial AC blends.
π° Part 3: 2026 Latest Tariff Rate Breakdown (Including Surcharges & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: 2025+ (Current Trade War Context)
π― 1. 2903.49.00.00 ββ Saturated Fluorinated Hydrocarbon Derivatives
| Item | Content |
|---|---|
| Base Duty Rate | 3.7% (Ad Valorem) |
| Section 301 Surcharge | 0.0% (Exempt or not applicable for this specific subheading) |
| IEEPA/232 Surcharge | +10% (China-specific tariff) |
| Total Effective Rate | 13.7% |
| Tax Calculation | CIF Value Γ 13.7% |
| De Minimis Exemption | β Not Available (High risk of audit) |
| Legal Basis Path | HTSUS:2903.49 β IEEPA:9903.01.24 (10% Add-on) |
π Explanation:
- This is the most favorable classification if your product can be legally defined as a "saturated fluorinated acyclic derivative." - Note: Many commercial refrigerant blends are rejected for this category because they are "mixtures" of different HFCs, not pure derivatives.
π― 2. 3827.69.00.00 ββ Other Hydrofluorocarbons (HFCs)
| Item | Content |
|---|---|
| Base Duty Rate | 3.7% |
| Section 301 Surcharge | +25.0% (Section 301 List 3/4) |
| IEEPA/232 Surcharge | +10% (China-specific tariff) |
| Total Effective Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Exemption | β Not Available |
| Legal Basis Path | HTSUS:3827.69 β USITC:301 (25%) β IEEPA (10%) |
π Note:
- This is the standard classification for most modern AC refrigerants (R-410A, R-32 blends, etc.). - 38.7% is a high cost factor. Must be factored into FOB pricing.
π― 3. 3824.99.55.00 ββ Other Chemical Products (Residual/Catch-All)
| Item | Content |
|---|---|
| Base Duty Rate | 3.7% |
| Section 301 Surcharge | +25.0% |
| IEEPA/232 Surcharge | +10% |
| Total Effective Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Exemption | β Not Available |
| Legal Basis Path | HTSUS:3824.99 β USITC:301 (25%) β IEEPA (10%) |
π Explanation:
- Used if the mixture doesnβt fit specific HFC/HCFC headings. - Risk: CBP may reclassify this to 3827.69 if HFCs are identified.
π― 4. 3827.39.00.00 ββ Halogenated Hydrocarbons (HCFCs/Chlorinated)
| Item | Content |
|---|---|
| Base Duty Rate | 3.7% |
| Section 301 Surcharge | +25.0% |
| IEEPA/232 Surcharge | +10% |
| Total Effective Rate | 38.7% |
| Tax Calculation | CIF Value Γ 38.7% |
| De Minimis Exemption | β Not Available |
| Legal Basis Path | HTSUS:3827.39 β USITC:301 (25%) β IEEPA (10%) |
π Warning:
- If your mixture contains Chlorine (Cl) (e.g., R-22, R-408A), it falls here. - Some HCFCs may face phase-out restrictions under Montreal Protocol, requiring additional EPA documentation.
π οΈ Part 4: Customs Clearance Practical Advice (Battle-Tested Guide)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Mandatory? | Description |
|---|---|---|
| β MSDS (Safety Data Sheet) | βοΈ | Must include exact chemical composition (percentages of each HFC/HCFC). |
| β Technical Specification Sheet | βοΈ | Lists boiling point, pressure, GWP, ODP. |
| β Commercial Invoice | βοΈ | Must state "Refrigerant Mixture" and HS Code. |
| β Bill of Lading (B/L) | βοΈ | Clear description of goods. |
| β EPA Section 608 Compliance (If Applicable) | βοΈ | For refrigerants with ODP > 0 or specific HFC restrictions. |
| β Certificate of Origin (CO) | βοΈ | To prove origin (China) and apply correct tariff. |
β 2. Declaration Tips (Crucial for Avoiding Penalties)
π₯ "Be Specific, Be Accurate, Don't Guess!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| R-410A (50/50 R-32/R-125) | 3827.69.00.00 - "Hydrofluorocarbon Mixture for Refrigeration" |
"Refrigerant Gas" β Vague, leads to audit. |
| R-22 (Chlorinated) | 3827.39.00.00 - "Chlorofluorocarbon Refrigerant" |
Misclassifying as HFC (3827.69) β Penalties. |
| New Low-GWP Blends (e.g., R-454B) | 3827.69.00.00 - "HFC/HCFO Mixture" |
Using 2903.49 β Rejection. |
| Empty Cylinders | 7311.00.00.00 - "Iron/Steel Containers" |
Declaring as refrigerant β Tax on empty metal. |
β 3. Special Case Handling
| Scenario | Handling Advice |
|---|---|
| UN 1045 (Refrigerant Gases) | Ensure Hazardous Material Declaration is filed if shipping by air/sea. |
| Pressure Cylinders | Must comply with DOT (US) or IMDG (Sea) packaging regulations. |
| EPA SNAP Program | If the mixture contains newly approved substances, ensure they are on the EPA SNAP List for commercial use. |
| Hybrid Mixtures | If it contains both HCFC and HFC, declare based on the primary component or as a mixture under 3827. |
π Part 5: Global Market Clearance Comparison (2026)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3827.69.00.00 |
38.7% (3.7% + 25% + 10%) | EPA + DOT | High tariffs, strict EPA rules. |
| π¨π³ China | 3827.69.00.00 |
0% (Often 0% for HFCs) | CCC (if applicable) | No 301 tariffs for imports into China. |
| πͺπΊ EU | 3824.99 or 2903 |
0% (Most Free Trade) | CE + F-Gas Regulation | F-Gas certification required for HFCs. |
| π¬π§ UK | 3827.69 |
0% | UKCA + F-Gas | Post-Brexit rules align with EU F-Gas. |
| π―π΅ Japan | 3827.69 |
0% | PSE (if applicable) | Low base tariffs, but strict safety checks. |
π Conclusion:
- USA is the highest cost market due to the 35%+ additive tariffs.
- EU/UK/Japan are more tariff-friendly but have strict environmental regulations (F-Gas).
π Part 6: Common Errors & Pitfalls (Lesson Learned)
β Error 1: Declaring "Refrigerant" under 2903.49 without proof of being a "pure derivative."
π Consequence: CBP reclassifies to 3827.69 β Back taxes + 10% penalty.
β Error 2: Mixing R-22 (HCFC) and R-410A (HFC) in one shipment without separate declaration.
π Consequence: Complex duty calculation errors β Delays.
β Error 3: Using "General Chemical Mixture" for HS Code.
π Consequence: Audit β Demand for MSDS and chemical analysis.
β Correct Approach:
"HFC Refrigerant Mixture, R-410A, 11.3kg Cylinder, UN 1045, EPA Compliant, HS Code: 3827.69.00.00"
π― Part 7: Conclusion: Professional Clearance Saves Money!
π― Remember the Rules:
πΉ "3827.69 is the King for HFCs" (38.7% Total Rate in US).
πΉ "2903.49 is the Trap" (Only for pure derivatives, not blends).
πΉ "Always check EPA & MSDS" (No documentation = No clearance).
π Pro Tip:
If your refrigerant mixture is low-GWP (e.g., R-32, R-454B), it still falls under 3827.69.00.00 in the US, so the 38.7% tariff applies.
Recommend Advance Ruling from CBP if the mixture is proprietary or new, to avoid classification disputes.
π£ Immediate Action:
π Contact Customs Broker + Provide MSDS + Verify Chemical Composition
π Ensure Smooth Clearance, Avoid 38.7% Surprise!
β¨ Professional Customs, Start with Precise Classification!
πΌ Your Bottom Line Depends on This 10-Digit 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) 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.