Silicone Drain Pad
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3924104000 | 13.4% | CN | US | Official Doc |
| 4016990500 | 20.9% | CN | US | Official Doc |
| 4016910000 | 37.7% | CN | US | Official Doc |
| 3924901050 | 13.3% | CN | US | Official Doc |
| 3924104000 | 13.4% | CN | US | Official Doc |
AI Analysis
π§οΈ Silicone Drain Pads (Silicone Mat for Kitchen/Bath)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
π I. Product Definition & Classification: Do You Really Understand "Silicone Drain Pad"?
A Silicone Drain Pad is a kitchen or bathroom accessory designed to hold wet items (dishes, glasses, fruit) and allow water to drain through or around the pad into a sink or tray. In international trade, classification depends heavily on the exact material composition (100% Silicone vs. Silicone-Coated vs. Plastic/Synthetic Resin) and form factor.
β οΈ Key Classification Dilemma:
- Is it "Vulcanized Rubber/Elastomer" (often used for 100% silicone rubber products) β Chapter 40?
- Is it "Plastic/Artificial Plastic" (many "silicone" pads are actually PVC/PP/TPE blends) β Chapter 39?
- Crucial Note: In customs classification, "Silicone" is often treated under 4016 (Articles of vulcanized rubber other than hard rubber) if it is true elastomeric silicone, OR under 3924 (Tableware, kitchenware... of plastics) if it is synthetic resin-based. Misclassification here leads to massive tariff differences.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on the provided data, here are the four potential classifications for Silicone Drain Pads:
| HS Code | Product Description | Material Basis | Application | Why This Code? |
|---|---|---|---|---|
4016.99.05.00 |
Silicone Drain Pad | Vulcanized Rubber / Elastomer | Household items | Classified as other articles of vulcanized rubber. If the material is confirmed as 100% silicone rubber (an elastomer), it falls here. |
4016.91.00.00 |
Silicone Drain Pad | Sulfur-Cured Rubber Products | Pads/Mats | Specifically for "Pads, mats, and similar articles" of vulcanized rubber. High tax due to specific sub-category. |
3924.90.10.50 |
Silicone Drain Pad | Plastic / Synthetic Resin | Household Mats | If the product is made of synthetic resin (e.g., TPE, PVC, PP) marketed as "silicone-like" or composite, it falls under "Other tableware/kitchenware of plastics." |
3924.10.40.00 |
Silicone Drain Pad / Kitchen Mat | Plastic / Synthetic Material | Household Items | Specifically for "Tableware and kitchenware" of plastics. If the pad is considered kitchenware, this is a strong candidate for plastic-based materials. |
π Critical Distinction:
- True Silicone (Elastomer): Often categorized under 4016 (Rubber) in some jurisdictions, but frequently confused with plastics.
- Synthetic Plastic/Resin: Most commercial "silicone" mats on Amazon are actually TPE (Thermoplastic Elastomer) or PVC, which are legally classified as Plastics (3924) in many customs systems unless certified as pure silicone rubber.
- Tax Impact: The difference between 13.3% (Plastic) and 37.7% (Specific Rubber Pad) or 20.9% (General Rubber) is significant.
π° III. 2026 Latest Tariff Rate Breakdown (Including Additional Duties & Policy Surcharges)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: 2025/2026 (Current Trade War Tariffs Apply)
π― 1. 4016.99.05.00 ββ Articles of Vulcanized Rubber (Other)
| Item | Content |
|---|---|
| Base Tariff | 3.4% |
| Section 301 Additional Duty | 7.5% |
| Section 122 Duty (China-Specific) | 10% |
| Total Tariff | 20.9% |
| Tax Calculation | CIF Value Γ 20.9% |
| De Minimis Eligibility | β No (Deny de minimis for China-origin rubber/plastic items in many contexts) |
| Legal Basis Path | HTSUS:4016.99.05 β 301_Tariff:7.5% β Section_122:10% |
π Explanation:
- This code applies if the pad is classified as Vulcanized Rubber (not hard rubber).
- Section 122 is a specific tariff for certain Chinese rubber/plastic goods.
- Total 20.9% is moderately high but lower than the plastic pad alternative in some cases.
π― 2. 4016.91.00.00 ββ Pads, Mats of Vulcanized Rubber
| Item | Content |
|---|---|
| Base Tariff | 2.7% |
| Section 301 Additional Duty | 25.0% |
| Section 122 Duty (China-Specific) | 10% |
| Total Tariff | 37.7% |
| Tax Calculation | CIF Value Γ 37.7% |
| De Minimis Eligibility | β No |
| Legal Basis Path | HTSUS:4016.91.00 β 301_Tariff:25% β Section_122:10% |
π Warning:
- This is the highest tariff option!
- If customs classifies your "silicone" pad specifically as a mat/pad of vulcanized rubber (not general article), you pay 25% Section 301 instead of 7.5%.
- Risk: High. If your product is physically a mat/pad, customs may prefer this code over 4016.99.05.00.
π― 3. 3924.90.10.50 ββ Plastic Tableware/Kitchenware (Other)
| Item | Content |
|---|---|
| Base Tariff | 3.3% |
| Section 301 Additional Duty | 0.0% |
| Section 122 Duty (China-Specific) | 10% |
| Total Tariff | 13.3% |
| Tax Calculation | CIF Value Γ 13.3% |
| De Minimis Eligibility | β No (Check specific de minimis rules, but typically Section 122 negates it for China) |
| Legal Basis Path | HTSUS:3924.90.10 β 301_Tariff:0% β Section_122:10% |
π Explanation:
- This is the lowest total tariff option.
- It applies if the product is classified as Plastic/Synthetic Resin (e.g., TPE, PVC, PP) and as Other kitchenware.
- Key Advantage: 0% Section 301 duty! Only Base + Section 122.
π― 4. 3924.10.40.00 ββ Tableware/Kitchenware of Plastics
| Item | Content |
|---|---|
| Base Tariff | 3.4% |
| Section 301 Additional Duty | 0.0% |
| Section 122 Duty (China-Specific) | 10% |
| Total Tariff | 13.4% |
| Tax Calculation | CIF Value Γ 13.4% |
| De Minimis Eligibility | β No |
| Legal Basis Path | HTSUS:3924.10.40 β 301_Tariff:0% β Section_122:10% |
π Explanation:
- Very similar to3924.90.10.50but under the specific "Tableware/Kitchenware" heading.
- Also benefits from 0% Section 301.
- Total 13.4% is nearly identical to 13.3%, but slightly higher by 0.1%.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Documentation Checklist (Non-Negotiable)
| Document | Required? | Notes |
|---|---|---|
| β Material Composition Certificate | βοΈ Yes | Must specify % of Silicone vs. Plastic (TPE/PVC). If >80% Silicone, argue for 4016. If mixed, argue for 3924. |
| β Product Photos (Lifestyle & Detail) | βοΈ Yes | Show flexibility, texture, and usage. Helps prove it's a "drain pad" not a "rubber sheet." |
| β Commercial Invoice | βοΈ Yes | Clearly state: "Silicone Drain Pad, Material: TPE/Silicone Blend, HS Code: XXXX" |
| β Customs Ruling (Advance Ruling) | βοΈ Highly Recommended | Apply for an Advance Ruling from CBP to lock in the 13.3% rate (3924) instead of risking the 37.7% rate. |
| β Certificate of Origin | βοΈ Yes | To prove China origin and apply Section 122 correctly. |
β 2. Strategic Declaration Tips (Key Mnemonics)
π₯ βPlastic Zero, Rubber High, Section 122 Always!β
Translation:
- If you can legally classify as Plastic (3924), you get 0% Section 301.
- If you are forced to classify as Rubber (4016), you pay 7.5% or 25% Section 301.
- Section 122 (10%) applies to ALL four codes for China-origin goods.
| Scenario | Recommended HS Code | Total Tariff | Strategy |
|---|---|---|---|
| TPE/PVC/PP Pad (Most Common) | 3924.90.10.50 |
13.3% | Best Option! Declare as "Synthetic Resin Mat." Provide material test report. |
| True Silicone Rubber Pad | 4016.99.05.00 |
20.9% | If material is 100% Silicone. Argue against 4016.91 (mat) by showing it's a general household item. |
| True Silicone Mat/Pad (High Risk) | 4016.91.00.00 |
37.7% | Avoid! Only if customs insists it's a "mat" of vulcanized rubber. Try to reclassify to 4016.99. |
| Kitchenware Plastic | 3924.10.40.00 |
13.4% | Good backup if 3924.90 is rejected. |
β 3. Special Cases & Handling
| Case | Handling Advice |
|---|---|
| Hybrid Material (Silicone + Plastic) | Declare as Plastic (3924) if plastic is the primary structural component or if the product is not 100% vulcanized silicone. |
| "Food Grade" Claim | Must provide FDA compliance documents. Does not change HS code, but prevents product rejection. |
| Set with Trays | If sold as a "Dish Rack Set," ensure the drain pad is not declared separately with a higher tariff. Bundle under the main article if possible. |
| Customs Audit | If audited on material, provide a Lab Test Report (FTIR) proving it is TPE/PVC, not vulcanized rubber. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Notes |
|---|---|---|---|
| πΊπΈ United States | 3924.90.10.50 |
13.3% | Best Rate. Avoid 4016.91 (37.7%) at all costs. Section 301 is 0% for plastics. |
| π¨π³ China (Import) | 3924.90.10.50 |
6.5% | Standard import tariff. No Section 122/301. |
| πͺπΊ European Union | 3924.10 |
4.2% | No Section 122/301. Standard EU tariff. |
| π¬π§ United Kingdom | 3924.10 |
4.0% | Post-Brexit tariff. |
π Conclusion:
- US Market is the most complex due to Section 301 and Section 122.
- Plastic classification (3924) is significantly cheaper than Rubber classification (4016) for China-origin goods.
- Verify Material! If your product is truly silicone, you may still argue for 3924 if itβs a synthetic blend or if customs practice in your port favors plastic for "silicone-like" items.
π VI. Common Mistakes & Pitfalls (Blood & Tears Lessons)
β Mistake 1: Declaring a TPE/PVC Pad as 4016.99.05.00
π Consequence: Pay 20.9% instead of 13.3%. You overpaid 7.6%!
β Mistake 2: Declaring a Silicone Pad as 4016.91.00.00
π Consequence: Pay 37.7% instead of 20.9% or 13.3%. Massive overpayment!
β Mistake 3: Assuming "Silicone" = 3924
π Consequence: If customs proves itβs 100% vulcanized rubber, they may reclassify to 4016, leading to back taxes + penalties.
β
Fix: Get a Customs Advance Ruling or Lab Test to support your classification.
β Mistake 4: Ignoring Section 122 (10%)
π Consequence: All four codes include this 10% duty. Do not forget to include it in your cost calculation!
π― VII. Conclusion: Professional Declaration, Save Money!
π― Remember the Mnemonic:
πΉ βPlastic is 13%, Rubber is 20-38%, Section 122 is 10% flat!β
πΉ βDonβt let βSiliconeβ fool youβitβs often Plastic (3924) in customsβ eyes!β
πΉ β301 is 0% for Plastic, 7.5% or 25% for Rubber. Choose 3924 if possible!β
π Pro Tip:
If your product is TPE (Thermoplastic Elastomer), it is legally a Plastic in many customs jurisdictions, not Rubber. Always declare under 3924 if you have the material certificate to support it. This saves you 7.6% to 24.4% in tariffs.
π£ Take Action Now:
π Contact Your Customs Broker: Provide the Material Test Report.
π Apply for Advance Ruling: Lock in the 13.3% rate for3924.90.10.50.
π Reduce Costs, Increase Profit!
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Your Cost is Calculated in Cents, But Your Profit is Calculated in Dollars!
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.