Silicone Face Mask
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3926909950 | 22.8% | CN | US | Official Doc |
AI Analysis
π Silicone Face Masks (Medical & Sanitary Use)
π HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy
π 1. Product Definition & Classification: What exactly is a "Silicone Face Mask"?
Silicone face masks, in the context of international trade and medical supplies, are distinct from cosmetic "mud masks" or "sheet masks." They are rigid or semi-rigid devices made primarily of silicone rubber, designed for: * Medical Positioning: Stabilizing a patientβs head or body during surgery, radiation therapy, or imaging. * Transport: Protecting patients during physical transport within medical facilities. * Sanitation/Protection: Acting as shields or barriers in specific medical waste handling or disinfection protocols.
Crucial Distinction:
β οΈ Key Differentiator:
- If the product is a rigid/semi-rigid device made of plastics (including silicone) for medical positioning, transport, or waste containment, it falls under Chapter 39 (Plastics).
- If it is a flexible, thin-film wearable primarily for infection control (surgical masks), it might fall under Chapter 90 (Medical Instruments) or 6307 (Other made-up articles).
- However, based strictly on the provided<DATA>, the product is classified as "Other articles of plastics... Face masks and shields, medical positioning or transport pads..." under HS Code 3926.90.99.50. This implies the item is a structural/plastic-based medical aid (e.g., a vacuum mask, positioning mold, or shield), NOT a disposable surgical mask.
π¦ 2. HS Code Classification Details (2026 Latest Tariff Authority Match)
| HS Code | Product Description | Application Scenario | Material Basis |
|---|---|---|---|
3926.90.99.50 |
Other articles of plastics: Face masks and shields, medical positioning or transport pads, medical waste containers or disinfectant wipes dispensers | Rigid silicone/plastic medical positioning devices, head immobilizers, transport shields | β Plastics (Silicone is considered a plastic/rubber article under HTSUS Chapter 39) |
π Critical Note:
- This HS Code excludes simple disposable surgical masks (which usually fall under 9020 or 6307).
- It specifically targets plastic articles used for medical positioning or shields.
- If your product is a flexible, non-rigid sheet without structural medical positioning function, this code may be incorrect. But for rigid silicone molds/shields, 3926.90.99.50 is the correct fit.
π° 3. 2026 Latest Tariff Rate Details (Including Surtax & Policy Add-ons)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: Current (2025-2026)
π― 1. 3926.90.99.50 ββ Silicone Plastic Medical Positioning/Shield Articles
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% |
| Additional Tariff (Section 301) | 0.0% |
| Total Tax Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0.0% = $0 |
| De Minimis Eligibility | β Yes (if value < $800) |
| Legal Basis Path | HTSUS:3926.90.99.50 β USITC:0% |
π Explanation:
- Unlike electronics or many consumer goods, medical plastic articles in this specific subheading currently enjoy 0% duty under the standard tariff schedule.
- No Section 301 (25%) or IEEPA (10%) surtax applies to this specific medical/plastic positioning article.
- Total Cost Impact: Zero additional tariff cost for customs duties. This is a significant advantage for cost-sensitive shipments.
π οΈ 4. Clearance Practical Advice (Combat Pitfalls Guide)
β 1. Required Documentation Checklist (None of these can be missing)
| Document | Required | Explanation |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must clearly state: "Silicone," "Medical Positioning," "Non-Disposable," "Rigid/Semi-Rigid." |
| β Product Photos | βοΈ | Show the product in use (if possible) to prove it is a positioning shield, not a cosmetic mask. |
| β Commercial Invoice | βοΈ | Description must match HS Code: "Silicone Medical Positioning Mask, Plastic Article, Chapter 39" |
| β Material Declaration | βοΈ | Confirm it is plastic/silicone, not fabric or non-woven (which would change the HS Code). |
| β FDA Registration (If applicable) | βοΈ | If intended for medical use, ensure the manufacturer is FDA-registered and the device is cleared/listed. |
β 2. Declaration Tips (Key Mnemonics)
π₯ "Plastic Not Fabric, Medical Not Cosmetic!"
| Scenario | Correct Declaration | Wrong Practice |
|---|---|---|
| Rigid Silicone Mold for Head Positioning | 3926.90.99.50 |
Misdeclared as "Surgical Mask" β 9020 (Different Tax/Clearance) |
| Flexible Silicone Sheet for Spa Use | 3926.90.99.99 (Other) |
Misdeclared as Medical β FDA Hold |
| Disposable Non-Woven Mask | 9020.30.00 or 6307.90 |
Misdeclared as Plastic Article β Misclassification |
π Warning:
- If customs officers suspect the item is a disposable surgical mask, they may reclassify it to 9020.30.00 (Masks for medical purposes), which may have different tariff implications and require FDA prior notice.
- Ensure the product description explicitly uses terms like "Positioning," "Shield," "Mold," or "Transport Pad" to justify Chapter 39.
β 3. Special Cases Handling
| Scenario | Handling Advice |
|---|---|
| OEM Medical Devices | Provide FDA 510(k) clearance number if available to prove medical use. |
| Cosmetic vs. Medical | If the mask is for beauty/spa use (e.g., heating mask), it should be declared as "Cosmetic Plastic Article" under 3926.90.99.99, not 3926.90.99.50. Misdeclaration can lead to FDA scrutiny. |
| Combined Shipment | If shipping with other plastic parts, ensure the invoice separates "Medical Positioning Masks" from other plastic goods to avoid bulk misclassification. |
π 5. Global Major Market Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff | Certification Requirement | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 3926.90.99.50 |
0% | FDA (if medical), CPC (if children's) | 0% duty advantage |
| π¨π³ China | 3926.90.99.90 |
5-10% | N/A | Import duty applies |
| πͺπΊ EU | 3926.90.97 |
0-4% | CE (if medical), REACH | No additional surtax |
| π¬π§ UK | 3926.90.90 |
0-4% | UKCA | Post-Brexit rules |
| π¦πΊ Australia | 3926.90.90 |
5% | TGA (if medical) | No surtax |
π Conclusion:
- The USA offers 0% duty for this specific medical plastic article, making it highly cost-effective.
- However, regulatory compliance (FDA) is the main hurdle, not tariff cost. Ensure your product meets FDA 21 CFR requirements if marketed as a medical device.
π 6. Common Errors & Pitfalls Guide (Lessons Learned)
β Error 1: Declaring a cosmetic silicone face mask as medical positioning mask
π Consequence: FDA inspection, product seizure, or penalty for false medical claims.
π Fix: Use "Cosmetic Plastic Article" (3926.90.99.99) for beauty products.
β Error 2: Declaring a disposable non-woven mask as plastic article
π Consequence: Misclassification, potential duty adjustment, and delay.
π Fix: Disposable masks are Textiles (6307) or Medical Instruments (9020), not plastics.
β Error 3: Omitting FDA Registration for medical-grade silicone shields
π Consequence: Hold at customs, request for prior notice, or refusal of entry.
π Fix: Include FDA Establishment Registration Number in documentation.
β Correct Practice:
"Silicone Medical Positioning Mask, Rigid, Plastic Article, FDA Cleared, Chapter 39, Model XYZ, 0% Duty"
π― 7. Conclusion: Professional Declaration, Save Time, Reduce Cost!
π― Remember the Mnemonic:
πΉ "Plastic, Not Fabric; Medical, Not Cosmetic!"
πΉ "HS Code 3926, Zero Duty, But FDA Still Required!"
πΉ "Positioning Shield, Not Disposable Mask!"
π Pro Tip:
If your silicone mask is flexible and non-medical (e.g., for spa use), do NOT use 3926.90.99.50. Use 3926.90.99.99 (Other) to avoid FDA medical claims scrutiny. For medical positioning, ensure you have FDA clearance to prevent clearance delays.
π£ Immediate Action:
π Contact your customs broker + Provide Product Photos + Confirm Medical/Cosmetic Intent
π Ensure 0% Duty clearance by accurate classification!
β¨ Professional Clearance, Starts with Accurate Classification!
πΌ Your Every Penny is Worth Calculating!
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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.