Sodium Carboxymethyl Cellulose Food Grade
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 3505100092 | 0.0% | CN | US | Official Doc |
| 2106909998 | 16.4% | CN | US | Official Doc |
| 3505100045 | 0.0% | CN | US | Official Doc |
| 3912310010 | 41.4% | CN | US | Official Doc |
| 3505100045 | 0.0% | CN | US | Official Doc |
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AI Analysis
π§ͺ Sodium Carboxymethyl Cellulose (CMC) - Food Grade
π HS Code Reference & Customs Clearance Guide | 2024/2026 Latest Tariff Analysis | Professional Clearance Strategy
π 1. Product Definition & Classification: Do You Really Understand "CMC"?
Sodium Carboxymethyl Cellulose (CMC) is a versatile water-soluble ether of cellulose. In international trade, its classification depends heavily on its intended use and purity grade. It is primarily used as a thickener, stabilizer, or emulsifier in food, but also functions as a modified starch derivative in industrial applications.
Key Distinction for Food Grade: * As a Food Additive/Admixture: If marketed specifically for human consumption, it often falls under Chapter 21 (Miscellaneous edible preparations). * As a Modified Starch/Derivative: If classified based on its chemical nature as a cellulose derivative, it may fall under Chapter 35 or Chapter 39.
β οΈ Critical Classification Point:
- If the product is explicitly labeled "Food Grade" and intended for direct human consumption β Chapter 21 is the most common "Food Product" route.
- If classified strictly by material (cellulose derivative) without food designation β Chapter 35 (Modified Starches) or Chapter 39 (Plastics/Cellulose Derivatives).
π¦ 2. HS Code Classification Details (Based on Provided Data)
| HS Code | Product Description | Summary from Data | Total Tax | Tax Detail |
|---|---|---|---|---|
2106.90.99.98 |
Miscellaneous Edible Preparations | CMC as a food additive/mixture, fits "Other food preparations" | 16.4% | Base: 6.4%, Additional: 0.0%, Section 301: 10% |
3505.10.00.92 |
Modified Starches | CMC as a derivative of modified starch, fits "Other modified starches" | 0.7Β’/kg + 17.5% | Base: 0.7Β’/kg, Additional: 7.5%, Section 301: 10% |
3505.10.00.45 |
Modified Starches | CMC as a modified starch/derivative, fits "Other" | 0.7Β’/kg + 17.5% | Base: 0.7Β’/kg, Additional: 7.5%, Section 301: 10% |
3912.31.00.10 |
Cellulose Derivatives (Plastics) | Material matches CMC and its salts, fits "Other cellulose ethers" | 41.4% | Base: 6.4%, Additional: 25.0%, Section 301: 10% |
π Key Observation:
-2106.90.99.98is often the most cost-effective for food-grade CMC if properly declared as a food preparation, with a flat 16.4% rate (no specific duty per kg).
-3505.10.00.92/.45involve a specific duty (0.7Β’/kg) plus ad valorem tax, totaling 17.5%.
-3912.31.00.10has the highest additional tariff (25%), leading to a total of 41.4%. Avoid this unless strictly required by customs.
π° 3. 2024/2026 Latest Tariff Rate Breakdown (Including Surcharges)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Time: Ongoing (Section 301 & 122 Clauses)
π― 1. 2106.90.99.98 ββ Food Additive/Preparation (Recommended for Food Grade)
| Item | Content |
|---|---|
| Base Duty | 6.4% (ad valorem) |
| Section 301 Additional Duty | +10% (ιε―ΉδΈε½δΊ§εοΌ122ζ‘ζ¬Ύ) |
| Other Additional Duties | 0.0% |
| Total Tax Rate | 16.4% |
| Tax Calculation | CIF Value Γ 16.4% |
| De Minimis Eligibility | β No (Deny de minimis for Section 301 goods) |
| Legal Basis Path | USITC:2106.90.99.98 β Section 301: 10% |
π Explanation:
- This is the simplest structure with no specific duty per kg.
- Ideal for Food Grade CMC where the primary function is as an ingredient.
- Total 16.4% is significantly lower than the 41.4% or 17.5%+kg rates.
π― 2. 3505.10.00.92 / 3505.10.00.45 ββ Modified Starches
| Item | Content |
|---|---|
| Specific Duty | 0.7Β’/kg |
| Base Ad Valorem | 7.5% |
| Section 301 Additional Duty | +10% |
| Total Tax Rate | 0.7Β’/kg + 17.5% |
| Tax Calculation | (CIF Value Γ 17.5%) + (Weight in kg Γ $0.007) |
| De Minimis Eligibility | β No |
| Legal Basis Path | USITC:3505.10.00 β Section 301: 10% |
π Note:
- Suitable if CMC is classified as a modified starch derivative rather than a food additive.
- The specific duty (0.7Β’/kg) adds up quickly for high-volume shipments.
- Total effective rate depends on value density; often higher than 16.4% for high-value food-grade products.
π― 3. 3912.31.00.10 ββ Cellulose Derivatives (High Risk)
| Item | Content |
|---|---|
| Base Duty | 6.4% |
| Section 301 Additional Duty | +25% (25% punitive) |
| Section 122/Other | +10% |
| Total Tax Rate | 41.4% |
| Tax Calculation | CIF Value Γ 41.4% |
| De Minimis Eligibility | β No |
| Legal Basis Path | USITC:3912.31.00.10 β Section 301: 25% |
π Warning:
- This classification triggers the highest additional tariff (25%).
- Avoid this classification for food-grade CMC unless explicitly required.
- Total 41.4% makes it financially unviable for most commercial imports.
π οΈ 4. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
β 1. Documentation Checklist (Mandatory)
| Document | Required | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Must state "Food Grade," CAS number (9004-32-4), and intended use. |
| β FDA Registration | βοΈ | Proof of FDA facility registration for food additives. |
| β Certificate of Analysis (COA) | βοΈ | Purity level, heavy metals, microbial limits. |
| β Commercial Invoice | βοΈ | Clearly describe as "Sodium Carboxymethyl Cellulose, Food Grade" |
| β Origin Certificate | βοΈ | To prove country of origin (China) for Section 301 applicability. |
| β HS Code Pre-Ruling | βοΈ | Highly Recommended to avoid misclassification penalties. |
β 2. Declaration Tips (Key Mantra)
π₯ "Food Grade, Chapter 21; Starch Derivative, Chapter 35; Avoid Chapter 39!"
| Scenario | Correct Declaration | Incorrect Declaration |
|---|---|---|
| Food Grade CMC | 2106.90.99.98 (16.4%) |
3912.31.00.10 (41.4%) β Overpay! |
| Industrial Grade CMC | 3505.10.00.45 (0.7Β’/kg + 17.5%) |
2106.90.99.98 β Misclassification Risk |
| Bulk CMC for Food Use | 2106.90.99.98 |
3505.10.00.92 β Higher Specific Duty |
β 3. Special Situations
| Situation | Handling Advice |
|---|---|
| OEM Food Products | Provide clientβs FDA registration and food safety plan. |
| Mixed Shipments | Declare CMC separately; do not mix with non-food chemicals. |
| Small Sample Imports | Still subject to de minimis restrictions; declare fully. |
| Origin Change | If sourced from Vietnam/Thailand, check for Section 301 exemptions (rare for food additives). |
π 5. Global Market Comparison (2024/2026)
| Country/Region | Recommended HS Code | Tariff | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 2106.90.99.98 |
16.4% | FDA | Best for food grade. Avoid 3912. |
| π¨π³ China | 2106.90.99.98 |
~5-6% | GB Standard | Lower tariffs, but check import quotas. |
| πͺπΊ EU | 2106.90 (varies) |
0-6% | EFSA Approval | Strict food safety standards. |
| π―π΅ Japan | 2106.90 |
5-10% | FSSAI | Requires JAS certification for organic. |
π Conclusion:
- USA offers a clear path via Chapter 21 for food-grade CMC at 16.4%.
- Avoid Chapter 39 (3912.31.00.10) due to the 25% punitive tariff.
- Pre-Ruling is essential to confirm2106.90.99.98eligibility for your specific product.
π 6. Common Mistakes & Pitfalls (Lessons Learned)
β Mistake 1: Declaring Food Grade CMC as 3912.31.00.10
π Consequence: 41.4% tariff β Overpayment by ~25%!
β Mistake 2: Ignoring "Food Grade" Label
π Consequence: Customs may classify as industrial (3505) β Specific duty + risk of rejection.
β Mistake 3: Missing FDA Documentation
π Consequence: Detention at border, potential destruction or re-export.
β Mistake 4: Using "Cellulose Ethers" without Food Declaration
π Consequence: Misclassification under 3912 β 25% additional tariff.
β Correct Approach:
"Sodium Carboxymethyl Cellulose, Food Grade, CAS 9004-32-4, For Use as Thickener in Food Products, FDA Registered"
π― 7. Conclusion: Professional Declaration, Save Money, Ensure Compliance
π― Remember the Mantra:
πΉ "Food Grade = Chapter 21 (16.4%); Industrial = Chapter 35 (17.5%+kg); Never 39 (41.4%)!"
πΉ "HS Code Determines Tax Rate; Declaration Determines Risk!"
π Pro Tip:
If your CMC is sourced from Vietnam, India, or Thailand, check for Section 301 exemptions or FTA benefits.
Recommendation: Apply for an Advance Ruling from CBP to confirm 2106.90.99.98 classification.
π£ Action Now:
π Contact a licensed customs broker + Provide FDA Docs + Request HS Code Pre-Ruling
π Ensure your Food Grade CMC clears smoothly, reduces costs, and meets all regulations!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every cent of your cost deserves precise calculation!
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.