Suction Cup Bathtub Cushion
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 4016910000 | 37.7% | CN | US | Official Doc |
| 4016990500 | 20.9% | CN | US | Official Doc |
| 6307908995 | 17.0% | CN | US | Official Doc |
| 6307909891 | 24.5% | CN | US | Official Doc |
| 3926305000 | 22.8% | CN | US | Official Doc |
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AI Analysis
π Suction Cup Bathtub Cushion: HS Code Classification & Customs Clearance Strategy
π HS Code Reference & Clearance Guide | 2026 Latest Tariff Analysis | Professional Level Entry Strategy
π Part 1: Product Definition & Classification β What Exactly Is a "Bathtub Cushion"?
A Suction Cup Bathtub Cushion is typically a comfort accessory designed to prevent slipping and provide ergonomic support during bathing. In international trade, its classification heavily depends on its primary material and structural composition.
Key Classification Dimensions: 1. Rubber/Elastomer Type: If made primarily of silicone, rubber, or other elastic materials with suction cups for fixation. 2. Textile/Fabric Type: If made primarily of cotton, polyester, or other textiles, often filled with foam. 3. Plastic/Composite Type: If the structural core is plastic or a mix of plastic/rubber components not classified elsewhere.
β οΈ Critical Distinction Point:
- If the product is soft, flexible, and rubber-based (common for non-slip mats/cushions) β Chapter 40 (Rubber).
- If the product is fabric-covered (soft, padded) β Chapter 63 (Other Textile Articles).
- If the product is rigid or plastic-heavy (unlikely for a "cushion" but possible for hard plastic backs) β Chapter 39 (Plastics) or Chapter 95/63 (General).
π¦ Part 2: HS Code Classification Details (2026 Latest Tariff Authority Comparison)
Based on common market variations and the provided data, here are the four most likely HS Code classifications:
| HS Code | Product Description | Applicable Scenario | Material/Structure |
|---|---|---|---|
4016.91.00.00 |
Other vulcanized rubber goods, other than hard rubber: Mats, rugs & carpeting; Mattresses, cushions & similar stuffed or upholstered articles | Rubber Cushions: Soft, flexible, rubber-based bath mats/cushions with suction cups. | β Vulcanized Rubber (Primary) |
4016.99.05.00 |
Other vulcanized rubber goods: Other household articles | General Rubber Household Items: Rubber-based bath accessories not fitting specific "mat/cushion" definitions strictly, or general rubber household aids. | β Vulcanized Rubber (General) |
6307.90.89.95 |
Other made-up textile articles: Other other | Textile/Fabric Cushions: Bath cushions covered in cotton, polyester, or microfiber, often with foam filling. | β Textile Fabric (Primary) |
6307.90.98.91 |
Other made-up textile articles: Other other | Generic Finished Textile Goods: A "catch-all" for finished textile products that don't fit other specific textile headings. | β Textile/Fabric (General) |
3926.30.50.00 |
Other articles of plastics and articles of other materials of headings 3901 to 3914: Other fittings for furniture, for walls, for floors or for ceilings | Plastic/Composite Accessories: If the cushion structure relies heavily on plastic components or is considered a "fitting" for the bathtub. | β Plastic (Primary) |
π Key Reminder:
- Rubber vs. Plastic: Rubber (4016) is elastic and vulcanized; Plastic (3926) is rigid or semi-rigid. A "cushion" is usually rubber or textile.
- Textile vs. Rubber: If the surface is fabric, it likely falls under6307. If itβs a solid rubber piece with suction cups, it falls under4016.
- Suction Cups: The presence of suction cups does not change the HS Code category itself but confirms its use as a "fixture" or "accessory."
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 November 10 onwards (including subsequent imports)
π― 1. 4016.91.00.00 β Rubber Mats, Rugs, Mattresses, Cushions
| Item | Content |
|---|---|
| Base Tariff | 2.7% (ad valorem) |
| Section 301 Surcharge | +25.0% (USITC Footnote 9903.88.01) |
| Section 122 Surcharge | +10.0% (IEEPA, targeting Chinese products) |
| Total Tariff | 37.7% |
| Tax Calculation | CIF Value Γ 37.7% |
| De Minimis Eligibility | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 β USITC:4016.91.00.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- Rubber bath cushions are considered consumer goods and are subject to the full 37.7% burden.
- This is a high tariff item. Importers must account for nearly 40% of the product value in taxes.
π― 2. 4016.99.05.00 β Other Rubber Household Articles
| Item | Content |
|---|---|
| Base Tariff | 3.4% (ad valorem) |
| Section 301 Surcharge | +7.5% (USITC Footnote 9903.88.01) |
| Section 122 Surcharge | +10.0% (IEEPA, targeting Chinese products) |
| Total Tariff | 20.9% |
| Tax Calculation | CIF Value Γ 20.9% |
| De Minimis Eligibility | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:4016.99.05.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- If customs classifies the item as a general household rubber item rather than a specific "cushion/mattress," the tariff drops significantly to 20.9%.
- This is a common optimization strategy if the product structure allows for broader classification.
π― 3. 6307.90.89.95 β Other Made-Up Textile Articles (Fabric Cushions)
| Item | Content |
|---|---|
| Base Tariff | 7.0% (ad valorem) |
| Section 301 Surcharge | +0.0% (Exempted for this specific subheading in some contexts, or lower tier) |
| Section 122 Surcharge | +10.0% (IEEPA, targeting Chinese products) |
| Total Tariff | 17.0% |
| Tax Calculation | CIF Value Γ 17.0% |
| De Minimis Eligibility | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:6307.90.89.95 |
π Explanation:
- If your product is fabric-covered (e.g., cotton/polyester with foam), this is the correct code.
- Lowest Base Tariff (7.0%) but still carries the 10% IEEPA surcharge.
- Total 17.0% is competitive compared to rubber options.
π― 4. 6307.90.98.91 β Other Made-Up Textile Articles (General Catch-All)
| Item | Content |
|---|---|
| Base Tariff | 7.0% (ad valorem) |
| Section 301 Surcharge | +7.5% (USITC Footnote 9903.88.01) |
| Section 122 Surcharge | +10.0% (IEEPA, targeting Chinese products) |
| Total Tariff | 24.5% |
| Tax Calculation | CIF Value Γ 24.5% |
| De Minimis Eligibility | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:6307.90.98.91 β FOOTNOTE:9903.88.01 |
π Explanation:
- Use this if the textile product doesn't fit the more specific6307.90.89.95.
- Higher than6307.90.89.95due to the 7.5% Section 301 surcharge.
π― 5. 3926.30.50.00 β Other Plastic Articles (Fittings/Accessories)
| Item | Content |
|---|---|
| Base Tariff | 5.3% (ad valorem) |
| Section 301 Surcharge | +7.5% (USITC Footnote 9903.88.01) |
| Section 122 Surcharge | +10.0% (IEEPA, targeting Chinese products) |
| Total Tariff | 22.8% |
| Tax Calculation | CIF Value Γ 22.8% |
| De Minimis Eligibility | β No (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.24 β USITC:3926.30.50.00 β FOOTNOTE:9903.88.01 |
π Explanation:
- Only applicable if the cushion is primarily plastic (e.g., hard plastic back with soft pads).
- Unlikely for a standard "cushion," but possible for composite products.
π οΈ Part 4: Customs Clearance Practical Advice (Battle-Tested Pitfall Avoidance Guide)
β 1. Required Documentation Checklist (Non-Negotiable)
| Document | Must Provide | Notes |
|---|---|---|
| β Product Specifications | βοΈ | Detail material composition (e.g., "100% Silicone," "Cotton Cover + Foam Fill"). |
| β Product Photos | βοΈ | Clear images of suction cups, material texture, and overall shape. |
| β Bill of Lading / Air Waybill | βοΈ | Ensure consignor/consignee details match invoice. |
| β Commercial Invoice | βοΈ | Must state "Suction Cup Bathtub Cushion" and HS Code. |
| β Packing List | βοΈ | List quantity, weight, and dimensions per carton. |
| β Material Declaration | βοΈ | Explicitly state if it contains rubber, textile, or plastic. |
| β IEEPA Compliance Statement | βοΈ | Confirm country of origin is China to trigger correct surcharges. |
β 2. Declaration Strategy (Key Mnemonics)
π₯ "Material First, Structure Second, Name Accurate, Tax Reduced!"
| Scenario | Correct Declaration | Incorrect Practice |
|---|---|---|
| 100% Silicone Rubber | 4016.91.00.00 (Cushion) or 4016.99.05.00 (Household) |
Misdeclare as plastic β Risk of penalty. |
| Fabric Cover + Foam | 6307.90.89.95 (Textile Article) |
Misdeclare as rubber β High tariff (37.7%). |
| Plastic Back + Rubber Pad | 4016.99.05.00 (If rubber is primary) or 3926.30.50.00 (If plastic is primary) |
Ambiguous description β Customs audit. |
| Mixed Package (Cushion + Suction Cups) | Declare as one unit | Split declaration β Higher administrative burden. |
β 3. Special Case Handling
| Situation | Handling Advice |
|---|---|
| OEM Custom Colors/Designs | Provide design proofs to confirm it's a finished good, not a raw material. |
| "Non-Slip" Claims | Emphasize material properties (rubber/textile) in declaration to avoid being classified as "hardware." |
| Set Packs (Cushion + Soap Dish) | If sold together, declare the principal item (Cushion) as the main HS Code. |
| Small Batches (< $800) | β No De Minimis Exemption for China-origin rubber/textile/plastic goods under current rules. |
π Part 5: Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 4016.91.00.00 or 6307.90.89.95 |
17.0% β 37.7% | FDA (if food-contact), CPSIA (if for kids) | High tariffs due to IEEPA/301. |
| π¨π³ China | 4016.91.00.00 or 6307.90.89.95 |
0% β 5% (Import Duty) | CCC (if applicable) | Low import duty, but high VAT. |
| πͺπΊ EU | 4016.91.00.00 or 6307.90.89.95 |
0% β 4.5% | CE (if applicable), REACH | No anti-dumping tariffs on bath cushions. |
| π¬π§ UK | 4016.91.00.00 or 6307.90.89.95 |
0% β 4.5% | UKCA (if applicable) | Post-Brexit tariffs apply. |
| π¨π¦ Canada | 4016.91.00.00 or 6307.90.89.95 |
0% β 6.5% | Health Canada (if applicable) | CUSMA may offer duty-free if originating. |
π Conclusion:
- USA is the highest-cost market due to IEEPA (10%) and Section 301 (7.5%-25%) surcharges.
- EU and Canada are more tariff-friendly.
- Material choice (Rubber vs. Textile) significantly impacts US tariffs.
π Part 6: Common Mistakes & Pitfall Guide (Lessons Learned)
β Mistake 1: Declaring a rubber cushion as a plastic article
π Consequence: Misclassification audit, back taxes, and penalties.
β
Fix: Be honest about material. Use 4016 for rubber.
β Mistake 2: Declaring a fabric cushion as a rubber article
π Consequence: Higher tariff (37.7% vs. 17.0%).
β
Fix: Use 6307.90.89.95 for textile covers.
β Mistake 3: Ignoring Section 122 (IEEPA 10%)
π Consequence: Unexpected tax bill at customs.
β
Fix: Always include the 10% IEEPA surcharge in cost calculations for China-origin goods.
β Mistake 4: Claiming De Minimis Exemption for China-origin goods
π Consequence: Package held, duties charged, and potential fines.
β
Fix: Assume full tax liability for China-origin shipments under $800.
π― Part 7: Conclusion β Professional Declaration, Cost Savings, Efficiency!
π― Remember the Mnemonic:
πΉ "Rubber Cushion: 37.7% (or 20.9%). Fabric Cushion: 17.0%. Plastic: 22.8%."
πΉ "Material Defines Code, Code Defines Tax."
π Pro Tip:
- If you want the lowest tariff, consider textile-based cushions (6307.90.89.95 at 17.0%) instead of pure rubber (4016.91.00.00 at 37.7%).
- Always verify material composition with your supplier.
- For high-volume imports, consider Advance Ruling from CBP to lock in the HS Code.
π£ Immediate Action:
π Consult a licensed customs broker.
π¦ Provide clear product photos and material specs.
π Optimize your supply chain to minimize tariff impact.
β¨ Professional Clearance Starts with Accurate Classification!
πΌ Every Cent Counts in International Trade!
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.