Theanine Separation from Black Tea Dust
CN β US| HS Code | Tariff Rate | Origin | Destination | Doc |
|---|---|---|---|---|
| 2106909987 | 16.4% | CN | US | Official Doc |
| 2106909973 | 16.4% | CN | US | Official Doc |
AI Analysis
π΅ Theanine Separation from Black Tea Dust
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Customs Strategy
π I. Product Definition & Classification: What is "Black Tea Dust"?
Black Tea Dust (BTD), often referred to as Fannings or Dust, is a specific grading of black tea. Unlike "Tea Leaves" (which consist of larger, whole, or broken leaves like Pekoe or OP), Dust consists of the finest particles resulting from the crushing of tea leaves during processing and sorting.
In international trade, Black Tea Dust is distinct from Herbal Teas or Tea Preparations. It is a natural agricultural product (processed tea), not a "food preparation" in the chemical sense, nor is it an unprocessed raw material if it has been dried, oxidized, and graded.
β οΈ Key Distinction for Customs Classification:
- If the product is purely ground black tea (Camellia sinensis) β It falls under Chapter 09 (Coffee, Tea, MatΓ© and Spices).
- If the product is mixed with other herbs, flavors, or extracts to form a "preparation for beverages" or "herbal infusion" β It falls under Chapter 21 (Food Preparations).
Note: The user's input query mentions "Theanine Separation from Black Tea Dust." This implies a processed product. If the final product is Theanine extract (pure L-Theanine), it is a chemical substance, not tea. If it is Black Tea Dust containing Theanine, it is still Tea. If it is a mixture of Black Tea Dust + other herbal ingredients for infusion, it falls under Chapter 21.
Given the provided <DATA> contains Chapter 21 items (2106.90.99), we must analyze if "Black Tea Dust" or "Theanine Separation from Black Tea Dust" fits into these specific HS Codes.
π¦ II. HS Code Classification Details (2026 Latest Tariff Authoritative Comparison)
The provided <DATA> only includes two HS Codes under 2106.90.99 ("Other food preparations n.e.s."):
| HS Code | Product Description | Applicability to "Black Tea Dust" or "Theanine Separation" |
|---|---|---|
2106.90.99.87 |
Other: Herbal teas and herbal infusions comprising mixed herbs | β Not Applicable unless the black tea dust is mixed with other herbs to create a "herbal infusion." Pure black tea dust is NOT a "herbal tea" (herbal teas are from plants other than Camellia sinensis). |
2106.90.99.73 |
Other: Preparations for the manufacture of beverages: Other | β Potentially Applicable if the "Theanine separation" results in a food preparation (e.g., a concentrated extract or powder used to make beverages, rather than being tea itself). |
π Critical Clarification:
- Pure Black Tea Dust: Should be classified under 0902.30.00.00 (Tea, partly or wholly fermented, in immediate packings of β€3 kg). It is NOT in the provided<DATA>.
- L-Theanine (Pure Extract): Should be classified under 2922.50.99.00 (Amino-acids and their esters; derivatives). It is NOT in the provided<DATA>.
- Mixed Herbal Tea Blend (with Black Tea Dust): If labeled as "Herbal Tea" and contains mixed herbs, it MIGHT be misclassified or correctly classified under2106.90.99.87by some customs authorities if the primary identity is "herbal."
- Tea Extract/Preparation: If the product is a theanine-enriched tea powder or a beverage preparation derived from black tea dust, it MAY fall under2106.90.99.73("Preparations for the manufacture of beverages").
Since the prompt restricts analysis to the provided <DATA>, we assume the product is being declared as one of the following:
1. A mixed herbal infusion containing black tea dust (2106.90.99.87).
2. A beverage preparation derived from black tea dust (2106.90.99.73).
π° III. 2026 Latest Tariff Rate Details (Including Surcharges, Policy Surcharges)
β Applicable Country: United States (US)
β Country of Origin: China (CN)
β Effective Date: November 10, 2025 (and subsequent imports)
π― 1. 2106.90.99.87 β Herbal Teas and Herbal Infusions Comprising Mixed Herbs
| Item | Content |
|---|---|
| Base Tariff Rate | 6.4% (ad valorem) |
| Section 301 Surcharge | 0.0% |
| IEEPA Surcharge | 0.0% |
| Total Tariff Rate | 6.4% |
| Tax Calculation | CIF Value Γ 6.4% |
| De Minimis Exemption | β Not Applicable (Section 321 de minimis does not apply to China-origin goods under certain conditions, but more importantly, Section 301 surcharges are 0% here, so de minimis might apply if value < $800, but for commercial import, full duty applies). |
| Legal Basis | HTSUS 2106.90.99.87; 19 CFR Part 178 (Section 301). |
π Explanation:
- "Base Tariff 6.4%" is the standard MFN rate for other food preparations.
- Section 301 Surcharge is 0.0%: This is critical. Unlike many Chinese goods, certain food preparations under 2106.90.99.87 are exempt from the 25% Section 301 tariff.
- IEEPA Surcharge is 0.0%: No additional emergency tariff applies.
- Total Cost Impact: Only the base 6.4% applies. This is significantly lower than the 45%+ rates for electronics or textiles.
π― 2. 2106.90.99.73 β Preparations for the Manufacture of Beverages: Other
| Item | Content |
|---|---|
| Base Tariff Rate | 0.0% |
| Section 301 Surcharge | 0.0% |
| IEEPA Surcharge | 0.0% |
| Total Tariff Rate | 0.0% |
| Tax Calculation | CIF Value Γ 0.0% |
| De Minimis Exemption | β Not Applicable (commercial import; however, 0% duty makes de minimis irrelevant for cost). |
| Legal Basis | HTSUS 2106.90.99.73; 19 CFR Part 178. |
π Explanation:
- Base Tariff 0.0%: This HS Code is duty-free under MFN treatment.
- Section 301 Surcharge is 0.0%: Exempt from the 25% tariff.
- IEEPA Surcharge is 0.0%: No additional tariff.
- Total Cost Impact: 0% Duty. This is the most advantageous classification for black tea-derived beverage preparations.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Guide)
β 1. Required Documentation Checklist (Missing items = Delay/Rejection)
| Document | Must Provide | Notes |
|---|---|---|
| β Product Specification Sheet | βοΈ | Clearly state: "Black Tea Dust," "L-Theanine Content," "Mixing Ratio with Herbs (if any)." |
| β Certificate of Analysis (COA) | βοΈ | For Theanine content. Proves it's a "preparation" or "herbal infusion." |
| β Ingredients List | βοΈ | Critical: If mixed with herbs, list all. If pure tea, declare as "Tea" (but note: Tea is NOT in <DATA>). |
| β Commercial Invoice | βοΈ | Must match HS Code description. E.g., "Herbal Tea Blend" for 2106.90.99.87 or "Beverage Preparation" for 2106.90.99.73. |
| β Proof of Origin | βοΈ | If claiming 0% or 6.4% rate, prove CN origin. |
| β FDA Prior Notice | βοΈ | All food/tea imports to the US require FDA Prior Notice. |
β 2. Declaration Tips (Key Mantra)
π₯ "Mix with Herbs? Say 'Herbal Tea'. Pure Extraction? Say 'Beverage Prep'. Pure Tea? Don't use these codes!"
| Situation | Correct HS Code | Wrong Code | Consequence |
|---|---|---|---|
| Black Tea Dust + Chrysanthemum + Goji Berry | 2106.90.99.87 (Herbal Tea) |
0902.30.00.00 (Tea) |
Customs may reclassify to 0902.30 (3% duty + 25% Section 301 = 28%) if deemed "tea blend," not "herbal." |
| Theanine Extract Powder for Soda/Juice | 2106.90.99.73 (Beverage Prep) |
2922.50 (Chemical) |
If sold as food ingredient, 2106.90.99.73 is 0% duty. 2922.50 may have different duties. |
| Pure Black Tea Dust (Fannings) | NOT IN <DATA> |
2106.90.99.87 |
Incorrect. Pure tea is 0902.30.00.00. Using 2106 will cause misdeclaration penalties. |
β οΈ Warning:
- Do NOT classify pure black tea dust as2106.90.99.87or2106.90.99.73. It is Tea (Chapter 09).
- Only if black tea dust is a minor ingredient in a herbal infusion or used as a base for a beverage preparation can these Chapter 21 codes be considered.
- If the product is L-Theanine pure extract, it is 2922.50, not in<DATA>.
β 3. Special Cases Handling
| Situation | Handling Advice |
|---|---|
| "Herbal Tea" with Black Tea Dust | If the product is marketed as "Herbal Tea" but contains Camellia sinensis, customs may scrutinize. Ensure the herbal ingredients are the primary weight component to justify 2106.90.99.87. |
| Theanine-Enriched Tea Powder | If Theanine is added to tea dust, it becomes a "food preparation." Declare as 2106.90.99.73 ("Preparation for beverages") to enjoy 0% duty. |
| Misclassification Risk | If declared as 2106.90.99.87 but contains >50% black tea dust, customs may reclassify to 0902.30.00.00 β 25% Section 301 surcharge applies β Total 28%. |
π V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code (if applicable) | Tariff | Certification | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 2106.90.99.73 |
0% | FDA Prior Notice | Best for beverage preparations. |
| πΊπΈ USA | 2106.90.99.87 |
6.4% | FDA Prior Notice | For herbal blends. |
| πͺπΊ EU | 0902.30 (Tea) |
0% | EU FSSC 22000 | Pure tea is duty-free in EU. |
| π¨π³ China | 0902.30 (Tea) |
5% | N/A | Pure tea imported to China. |
π Conclusion:
- USA:2106.90.99.73is duty-free (0%).
- EU/China: Pure tea is duty-free or low duty, but not in<DATA>.
- Critical: Ensure your product fits the exact description of the HS Code. If it's pure tea, do not use Chapter 21 codes.
π VI. Common Errors & Pitfall Guide (Blood Lessons)
β Error 1: Classifying pure black tea dust as 2106.90.99.87 ("Herbal Tea")
π Result: Customs reclassifies to 0902.30.00.00 β 28% total tariff (3% base + 25% Section 301) + Penalties.
β Error 2: Declaring L-Theanine pure extract as 2106.90.99.73
π Result: Misdeclaration. L-Theanine is a chemical/amino acid (2922.50). May face regulatory issues with FDA/USDA.
β Error 3: Using "Tea" in the description for 2106 codes
π Result: Customs officer will immediately flag as Chapter 09 product. Use "Beverage Preparation" or "Herbal Infusion Blend."
β Correct Approach:
"Black Tea Dust Infusion with Chrysanthemum and Goji Berry, Dried, 100g Pack" β
2106.90.99.87
"L-Theanine Enriched Black Tea Powder for Beverage Manufacturing" β2106.90.99.73
π― VII. Conclusion: Professional Declaration, Save Cost, Avoid Risks
π― Remember the Mantra:
πΉ "Pure Tea = Chapter 09. Mixed Herbs = Chapter 21.087. Beverage Prep = Chapter 21.073. 0% Duty is King!"
πΉ "Check Ingredients: If Tea is Main, Use 0902. If Herbs are Main, Use 2106.87. If Prep, Use 2106.73."
π Tips:
- If your product is pure black tea dust, do not use the provided <DATA> HS Codes. It is 0902.30.00.00 (3% base + 25% Section 301 = 28%).
- If you are extracting Theanine and selling the extract, it is 2922.50.99.00.
- If you are selling black tea dust mixed with herbs as an infusion, use 2106.90.99.87 (6.4% total).
- If you are selling a beverage preparation (e.g., tea powder for soda), use 2106.90.99.73 (0% total).
π£ Immediate Action:
π Consult a Customs Broker to confirm if your "Theanine Separation from Black Tea Dust" product is a chemical extract (2922), tea (0902), or food preparation (2106).
π Choose the correct HS Code to save up to 28% in tariffs!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Dollar Saved in Duties is Profit Earned!
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.