Vitamin B12 Cobalamin
CN โ USAI Analysis
๐ Vitamin B12 (Cobalamin): The Golden Standard in Health Supplements
๐ HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Clearance Strategy
๐ I. Product Definition & Classification: Do You Really Know "Vitamin B12"?
Vitamin B12, chemically known as Cobalamin, is a water-soluble vitamin essential for human health. In international trade, it is strictly categorized based on its state of purity and packaging:
-
Pure Chemical Substance (Single Vitamin):
- Refers to isolated Cobalamin (e.g., Cyanocobalamin, Methylcobalamin) with high purity (>90%), not mixed with other substances.
- Used by pharmaceutical companies or laboratories for formulation.
-
Mixed/Dosed Preparations:
- Refers to Vitamin B12 mixed with other vitamins (e.g., B-Complex), sugars, or excipients.
- Refers to pre-packaged dosage forms (tablets, capsules, liquids) intended for direct consumption.
โ ๏ธ Key Distinction Point:
- If it is a pure chemical powder for industrial/pharmaceutical use โ Classified under 2936.
- If it is a mixed preparation or dosage form for health purposes โ Classified under 3004.
- Never classify pure chemicals as "dietary supplements" if they are sold in bulk for further processing!
๐ฆ II. HS Code Classification Details (2026 Latest Tariff Authority Comparison)
| HS Code | Product Description | Applicable Scenario | Purity/State |
|---|---|---|---|
2936.28.00.00 |
Vitamins and their derivatives, pure (excluding those of 2936.10-2936.27) | Pure Vitamin B12 (Cyanocobalamin/Methylcobalamin) powder for pharmaceutical use | โ Pure (>90%) |
3004.90.60.00 |
Medicaments consisting of mixed or unmixed products for therapeutic/prophylactic uses, dosed or put up in retail packaging | Pure B12 in retail packaging (e.g., small bottles for direct sale) or dosed forms | โ ๏ธ Retail/Dosed |
3004.90.90.60 |
Other medicaments (including vitamins, but NOT pure single vitamins in bulk) | Mixed B12 (e.g., B-Complex, B12+Folic Acid) or formulated supplements | โ Mixed/Composite |
1302.39.00.00 |
Vegetable saps and extracts, pectic substances, pectinates, agar-agar, etc. | Incorrectly used โ B12 is synthetic/bacterial, not plant extract | โ Wrong |
๐ Critical Reminder:
-2936.28.00.00is for bulk pure chemicals. If you sell "Vitamin B12 Powder" to a factory, this is your code.
-3004series is for final consumer products. If you sell "B12 Gummies" or "B12 Shots," use3004.
- Misclassification Risk: Declaring bulk pure powder as3004(retail) may trigger scrutiny if packaging doesn't match. Declaring mixed supplements as2936(pure) will lead to seizure.
๐ฐ III. 2026 Latest Tariff Rate Details (Including Additional Taxes, Policy Surcharges)
โ Applicable Country: United States (US)
โ Origin: China (CN)
โ Effective Date: From November 10, 2025 (including subsequent imports)
๐ฏ 1. 2936.28.00.00 โโ Pure Vitamin B12 (Bulk/Industrial)
| Item | Content |
|---|---|
| Base Rate | 5.3% (ad valorem) |
| USITC Additional Duty | +25% (from USITC Footnote 9903.88.01) |
| IEEPA Additional Duty | +10% (targeting China/HK products, from Nov 10, 2025) |
| Total Tariff Rate | 45.3% (Approx. 5.3% + 25% + 10%) |
| Tax Calculation | CIF Value ร 45.3% |
| De Minimis Eligibility | โ Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9903.01.25 โ IEEPA:9903.01.24 โ USITC:2936.28.00.00 โ FOOTNOTE:9903.88.01 |
๐ Explanation:
- The 25% is from the Section 301 tariffs on chemical products.
- The 10% is from the IEEPA tariffs on generic goods.
- Total ~45.3% makes importing bulk pure B12 from China to the US highly cost-prohibitive unless sourced from Vietnam/Mexico.
๐ฏ 2. 3004.90.90.60 โโ Mixed Vitamin B12 Supplements (Retail/Formulated)
| Item | Content |
|---|---|
| Base Rate | 5.6% (ad valorem) |
| USITC Additional Duty | +25% |
| IEEPA Additional Duty | +10% |
| Total Tariff Rate | 45.6% |
| Tax Calculation | CIF Value ร 45.6% |
| De Minimis Eligibility | โ Not Eligible (deny_de_minimis) |
| Legal Basis Path | IEEPA:9901.25 โ IEEPA:9903.01.24 โ USITC:3004.90.90.60 โ FOOTNOTE:9903.88.01 |
๐ Note:
- Even if marketed as "Organic Vegan B12," if itโs a mixed supplement, it falls here.
- The rate is slightly higher due to the "Medicament" classification base rate.
๐ ๏ธ IV. Customs Clearance Practical Advice (ๅฎๆ้ฟๅๆๅ)
โ 1. Required Documents Checklist (Mandatory)
| Document | Required | Description |
|---|---|---|
| โ Certificate of Analysis (COA) | โ๏ธ | Must show purity, active ingredient % (e.g., Cyanocobalamin โฅ98%). Critical for distinguishing 2936 vs 3004. |
| โ Formula/Ingredients List | โ๏ธ | For 3004 items, exact breakdown is required. For 2936, just the chemical name. |
| โ Product Photos (Packaging & Label) | โ๏ธ | Must show "Supplement Facts" or "Chemical Grade" clearly. |
| โ FCC/USP Monograph Compliance | โ๏ธ | Proof of pharmaceutical grade (if applicable). |
| โ Commercial Invoice | โ๏ธ | Clearly state: "Pure Vitamin B12 (Cyanocobalamin)" or "Vitamin B12 Supplement Tablets". |
| โ Country of Origin Certificate | โ๏ธ | Essential for determining 301/IEEPA applicability. |
โ 2. Declaration Tips (Key Mnemonic)
๐ฅ "Pure is 2936, Mixed is 3004, Label Defines the Path!"
| Scenario | Correct HS Code | Wrong Practice |
|---|---|---|
| Bulk powder, white bag, "For Industrial Use" | 2936.28.00.00 |
Declaring as supplement โ Customs may reject due to lack of dosage info |
| Retail bottles, "Dietary Supplement" | 3004.90.90.60 |
Declaring as pure chemical โ Misdeclaration penalty |
| B12 + Folic Acid mix | 3004.90.90.60 |
Declaring as "Pure B12" โ Seizure |
| Liquid spray, "Energy Boost" | 3004.90.90.60 |
Declaring as "Food Additive" โ Wrong code |
โ 3. Special Cases
| Case | Handling Advice |
|---|---|
| OEM Private Label B12 | Provide client authorization + formula sheet. Avoid claiming "pharmaceutical grade" if not FDA NDC registered. |
| Vegan/B12 from Fermentation | Still 2936 or 3004 depending on purity/mix. Origin of source (bacterial vs synthetic) doesnโt change HS code. |
| Import for Clinical Trials | Apply for Personal Use Import Permit or Investigational New Drug (IND) exemption. May qualify for duty-free under specific research provisions. |
| Small Sample (<$800) | If shipped via courier (de minimis), B12 is EXCLUDED from de minimis exemption (deny_de_minimis). Must pay full duties even if under $800. |
๐ V. Global Market Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff Rate | Certification Requirements | Remarks |
|---|---|---|---|---|
| ๐บ๐ธ USA | 2936.28.00.00 / 3004 |
~45.3% (China) | FDA Compliance (GRAS/DMF) | Highest barrier due to 301/IEEPA |
| ๐จ๐ณ China | 2929.90.90 / 3004.90.99 |
5-10% | NMPA Registration (if drug) | Low tariff, strict registration |
| ๐ช๐บ EU | 2936.28 / 3004.90 |
0-6.5% | REACH Registration + GMP | No 301-type tariffs; REACH is key |
| ๐ฌ๐ง UK | 2936.28 / 3004 |
0-6.5% | MHRA Standards | Post-Brexit rules apply |
| ๐ฆ๐บ Australia | 2936.28 / 3004 |
0-5% | TGA Registration | Strict therapeutic goods regulations |
๐ Conclusion:
- USA is the most expensive market for Chinese B12 imports due to layered tariffs.
- EU/UK are favorable for tariffs but have strict REACH/Pharmaceutical compliance.
- Australia requires TGA listing for health claims, which is costly and time-consuming.
๐ VI. Common Mistakes & Pitfalls (Blood Lessons)
โ Mistake 1: Declaring "B12 Tablets" as "Chemical Powder" (2936)
๐ Consequence: Customs inspection reveals retail packaging โ Penalty + Back Taxes + Detention.
โ Mistake 2: Not declaring "De Minimis Exclusion" for B12
๐ Consequence: Even if under $800, duties are charged. Ignoring this leads to unexpected costs.
โ Mistake 3: Ignoring REACH/ECHA Registration for EU Imports
๐ Consequence: Goods held at EU border indefinitely. B12 is an existing substance, but high volume requires compliance.
โ Mistake 4: Using "Food Additive" HS Code for B12 Supplements
๐ Consequence: B12 is not classified as a standard food additive in many jurisdictions when sold as a supplement. Wrong code โ 10% penalty.
โ Correct Practice:
"Vitamin B12 (Cyanocobalamin), 98% Purity, Bulk Pack, For Pharmaceutical Use Only"
OR
"Vitamin B12 Supplement Tablets, 1000mcg, Retail Pack, Dietary Supplement, NSF Certified"
๐ฏ VII. Conclusion: Professional Declaration, Save Time, Reduce Costs!
๐ฏ Remember the Mnemonic:
๐น "Pure is 2936, Mixed is 3004, Label Defines the Path!"
๐น "USA Tariff is High, Origin Matters, De Minimis Doesn't Apply!"
๐น "HS Code Decides Fate, 45% Difference, Declare Wrong, Pay Extra!"
๐ Pro Tip:
If your B12 is originally manufactured in Vietnam, India, or Mexico, you may avoid IEEPA/301 tariffs (rate drops to 0-5%).
Recommend Advance Ruling or Pre-classification to confirm if your specific formulation qualifies as "Pure" vs "Mixed."
๐ฃ Immediate Action:
๐ Contact a licensed customs broker + Provide COA + Verify Country of Origin
๐ Ensure your B12 clears customs smoothly, avoids delays, and maximizes profit margins!
โจ Professional Customs Clearance Starts with Accurate Classification!
๐ผ Every Penny of Your Cost is Worth 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) โ Broad category of goods (e.g., Chapter 84: Machinery and Mechanical Appliances)
- Heading (4 digits) โ More specific grouping within the chapter
- Subheading (6 digits) โ Internationally standardized breakdown, used by all WCO member countries
- National subdivisions (8-10 digits) โ 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 โ The standard duty rate applied to WTO members
- General rate โ Applied to countries without trade agreements
- Trade remedy duties โ 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.