Whole Raw Milk
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π₯ Whole Raw Milk (Unprocessed Bovine Milk)
π HS Code Reference & Customs Clearance Guide | 2026 Latest Tariff Analysis | Professional Compliance Strategy
π I. Product Definition & Classification: What is "Whole Raw Milk"?
Whole Raw Milk refers to milk obtained from the milking of one or more cows, which has not undergone any heat treatment (pasteurization, UHT, sterilization) or homogenization, and retains its natural fat content (typically 3.5% - 4.0% milk fat). It is distinct from processed dairy products, powdered milk, or flavored milks.
β οΈ Key Distinction:
- Raw Milk: Unheated, natural state, high microbial risk. Often restricted or banned for direct human consumption in many jurisdictions (e.g., USA, parts of EU) unless sold under strict "farm-gate" or veterinary supervision.
- Processed Milk: Pasteurized, homogenized, or powdered β Classified under different HS codes (e.g., 0402, 0406).
π¦ II. HS Code Classification Details (2026 Latest Tariff Alignment)
| HS Code | Product Description | Applicable Scenario | Processing Status |
|---|---|---|---|
0401.10.00.00 |
Milk and cream, not concentrated nor containing added sugar or other sweetening matter, with a fat content by weight of not exceeding 1% | Low-fat raw milk (rare) | β Raw |
0401.20.00.00 |
Milk and cream, not concentrated nor containing added sugar or other sweetening matter, with a fat content by weight of more than 1% but not exceeding 6% | Standard Whole Raw Milk (most common) | β Raw |
0401.30.00.00 |
Milk and cream, not concentrated nor containing added sugar or other sweetening matter, with a fat content by weight exceeding 6% | Extra-high fat raw milk (e.g., buffalo, cream-style) | β Raw |
0402.21.00.00 |
Milk and cream, concentrated or containing added sugar or other sweetening matter, in the form of solids or paste, fat content >1.5% | Condensed milk (sweetened) | β Processed |
0406.90.00.00 |
Cheese and curd | Solid dairy products | β Processed |
π Key Reminder:
- Most Whole Raw Milk falls under0401.20.00.00(Fat content 1%-6%).
- If the fat content exceeds 6% (e.g., cream), use0401.30.00.00.
- Do NOT confuse with pasteurized milk (HS 0401.10β0401.90 is for raw milk; processed milk is generally 0402).
- Raw milk imports are heavily regulated due to food safety concerns (Brucellosis, Tuberculosis, E. coli, Salmonella).
π° III. 2026 Latest Tariff Rate Details (Including Surtaxes & Policy Add-ons)
β Applicable Country: United States (US)
β Origin: China (CN)
β Effective Date: 2025-11-10 onwards (including subsequent imports)
π― 1. 0401.20.00.00 β Whole Raw Milk (Fat 1%-6%)
| Item | Content |
|---|---|
| Base MFN Rate | 0% (ad valorem) |
| USITC Surtax (Section 301) | +25% (Footnote 9903.01.24) |
| IEEPA Surtax (China) | +10% (International Emergency Economic Powers Act, effective 2025-11-10) |
| Total Tariff Rate | 35% |
| Tax Calculation | CIF Value Γ 35% |
| De Minimis Exemption | β Not Eligible (deny_de_minimis) |
| Legal Pathway | IEEPA:9903.01.24 β USITC:0401.20.00.00 β FOOTNOTE:9903.01.24 |
π Explanation:
- Although dairy products often enjoy low base tariffs, Chinese-origin raw milk is subject to additional punitive tariffs.
- Total rate of 35% makes direct import of raw milk from China to the US commercially unviable due to high cost and regulatory hurdles.
- Raw milk is generally prohibited for human consumption in the US under FDA regulations, except for raw milk cheese (which has its own HS code and restrictions) or under state-level "raw milk" sales exceptions.
π― 2. 0401.10.00.00 β Skim Raw Milk (Fat β€1%)
| Item | Content |
|---|---|
| Base MFN Rate | 0% |
| USITC Surtax | +25% |
| IEEPA Surtax | +10% |
| Total Tariff Rate | 35% |
| Tax Calculation | CIF Γ 35% |
| De Minimis Exemption | β Not Eligible |
π Note:
- Same tariff structure as whole raw milk.
- Skim raw milk is rarely imported due to limited end-use.
π οΈ IV. Customs Clearance Practical Advice (Real-World Pitfall Avoidance)
β 1. Documentation Checklist (Mandatory)
| Document | Required | Notes |
|---|---|---|
| β Veterinary Health Certificate | βοΈ | Must be issued by the country of origin, confirming freedom from Brucellosis, TB, etc. |
| β FDA Prior Notice | βοΈ | Required for all food imports under Bioterrorism Act |
| β Labeling Compliance | βοΈ | Must comply with FDA food labeling rules (nutrition facts, allergens, country of origin) |
| β Commercial Invoice | βοΈ | Must clearly state "Whole Raw Milk, Bovine, Unprocessed" |
| β Bill of Lading | βοΈ | |
| β Certificate of Origin | βοΈ | |
| β Import Permit from FDA/USDA | βοΈ | Raw milk for human consumption is generally prohibited unless for specific exemptions (e.g., direct from farm to consumer in some states, or for industrial use) |
β 2. Declaration Tips (Key Mantra)
π₯ "Raw Milk β Processed Milk. Specify 'Raw'. Declare Fat %. Vet Cert is King!"
| Scenario | Correct Declaration | Wrong Approach |
|---|---|---|
| Whole Raw Milk (1.5%-4% fat) | 0401.20.00.00 |
Misclassified as 0402 (processed) β Penalty |
| Raw Milk for Cheese Making | 0401.20.00.00 + Note: "For Further Processing" |
Declare as "Food for Human Consumption" β Rejection |
| Pasteurized Milk | 0402.21.00.00 (if condensed/sweetened) or 0401.10/20 is incorrect |
Misclassifying as raw β Health risk & penalty |
| Raw Milk (Non-US Origin) | Check Country-Specific FDA Approval | Assume all raw milk is allowed β Illegal Import |
β 3. Special Cases & Handling
| Situation | Handling Advice |
|---|---|
| Raw Milk for Cheese Production | May be allowed if processed in a licensed facility. Declare as "Raw Milk for Further Processing" and provide facility license. |
| Raw Milk for Human Consumption (US) | Generally Prohibited by FDA for interstate commerce. Some states allow intrastate sales. Check state laws. |
| Raw Milk from Non-China Origin | Base MFN rate may still be 0%, but Surtax may not apply if origin is not China. However, 301 tariffs apply only to Chinese goods. |
| Raw Milk from Canada/Mexico | May qualify for USMCA/CUSMA preferential tariffs (0% duty). Verify origin rules. |
π V. Global Customs Clearance Comparison (2026 Latest)
| Country/Region | Recommended HS Code | Tariff (China Origin) | Certification Requirements | Notes |
|---|---|---|---|---|
| πΊπΈ USA | 0401.20.00.00 |
35% | FDA Prior Notice + Vet Cert | Human consumption generally banned for raw milk |
| πͺπΊ EU | 0401.10/20/30 |
0% (if quota) / 24% (out of quota) | EU Health Certificate | Raw milk for human consumption banned in most EU states |
| π¨π³ China | 0401.20.00.00 |
12% | NIF (National Inspection & Quarantine) Cert | Raw milk imports strictly controlled; mostly for processing |
| π¦πΊ Australia | 0401.20.00.00 |
5% | Biosecurity Import Permit | Raw milk allowed under strict conditions |
| π―π΅ Japan | 0401.20.00.00 |
0% (if quota) / 34.4% (out of quota) | Veterinary Certificate | Raw milk for human consumption prohibited |
π Conclusion:
- Most developed markets (USA, EU, Japan) prohibit raw milk for direct human consumption due to public health risks.
- Tariffs alone are not the biggest barrier; regulatory bans are.
- China-origin raw milk faces high tariffs (35%) and strict regulatory scrutiny.
π VI. Common Errors & Pitfall Guide (Blood & Tears Lessons)
β Error 1: Declaring Raw Milk as "Milk, Processed" (HS 0402)
π Consequence: Misclassification β FDA Rejection + Destruction of Goods
β Error 2: Importing Raw Milk for Human Consumption to the US without FDA Approval
π Consequence: Illegal Import β Seizure, Fines, and Potential Criminal Charges
β Error 3: Not Including Veterinary Health Certificate
π Consequence: Customs Hold β Delayed Release, Storage Fees, or Return
β Error 4: Misdeclaring Fat Content
π Consequence: Wrong HS Code β Tariff Discrepancy + Penalty
β Correct Approach:
"Whole Raw Cowβs Milk, Unpasteurized, Fat Content 3.5%, For Further Processing into Cheese, Source: [Country], FDA Prior Notice Filed"
π― VII. Conclusion: Professional Declaration Saves Costs and Ensures Compliance
π― Remember the Mantra:
πΉ "Raw Milk is Not Food for Humans in Most Countries. Declare 'For Processing'. Vet Cert is Essential."
πΉ "HS Code 0401.20 for Raw Whole Milk. 35% Tax for China. Donβt Risk Human Consumption Imports."
π Pro Tip:
If your raw milk is from Canada or Mexico, leverage USMCA for 0% Duty (if origin rules are met).
For human consumption, consider importing pasteurized milk (HS 0401/0402) instead, which is legally compliant and safer.
Always consult a licensed customs broker and FDA compliance expert before importing raw milk.
π£ Immediate Action:
π Contact a US Customs Broker + Prepare FDA Prior Notice + Vet Health Certificate
π Ensure full compliance to avoid costly seizures and delays!
β¨ Professional Customs Clearance Starts with Accurate Classification!
πΌ Every Dollar of Tariff and Every Day of Delay Counts!
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.